Background An estimated 481,000 workers were employed in the animal slaughtering  and processing industry in 2016, according to the Current Population  Survey, which is jointly sponsored by DOL’s Bureau of Labor Statistics  and the U.S. Census Bureau. There were 5,282 meat and poultry plants  in the United States, of which 4,133 conducted processing only, 14  conducted slaughter only, and 1,135 conducted both slaughter and  processing, as of February 2017, according to FSIS (see fig. 1). More  than 30 million beef cattle, 117 million hogs, 243 million turkeys, and 8  billion chickens were slaughtered in the United States in 2016, according  to USDA’s National Agricultural Statistics Service data. As of June 2017,  almost 7,500 FSIS inspectors worked in meat and poultry plants,  according to FSIS. These inspectors are generally exposed to the same  types of hazards as plant employees. Meat and poultry plants are generally designed for an orderly flow from  point of entry of the living animal to the finished food product (see fig. 2).  Typically, the animal is brought to the meat or poultry plant and taken to  the kill floor area, where the animal is rendered unconscious and  slaughter occurs. Workers and machines behead and eviscerate the  animal, among other things, after which it is chilled for several hours.  FSIS inspectors ensure that the carcass meets federal food safety  standards. Workers and machines then process the carcass and may  break it into small portions that can be transported directly to  supermarkets. Slaughter and processing of meat and poultry require  workers to perform a high number of repetitive motions. Although plants  have increased automation, much of the work is still done by hand using  saws, knives, and other tools. Federal Roles Related to  Meat and Poultry Worker  Safety and Health OSHA helps ensure safe and healthful working conditions for workers in  the meat and poultry industry and other industries, in part by setting and  enforcing workplace safety and health standards. To carry out its  responsibilities under the Occupational Safety and Health Act of 1970, as  amended (OSH Act), OSHA establishes workplace safety and health  standards; conducts inspections; investigates complaints from workers  and reports of fatalities and severe injuries at worksites; and offers  cooperative programs, training, and outreach, among other efforts.  OSHA is responsible for enforcing private sector employers’ compliance  with these standards in about half the states, while the remaining states  have assumed that responsibility under a state plan approved by OSHA.  These “state-plan states” adopt and enforce their own standards (which  must be “at least as effective” in providing safe and healthful employment  conditions as the federal standards). With respect to federal employers,  federal agencies are generally required to establish and maintain a  comprehensive and effective occupational safety and health program that  is consistent with OSHA’s standards. OSHA is generally responsible for  inspecting federal employers in all states, including state-plan states. As part of its enforcement, OSHA conducts on-site inspections of federal  and non-federal employers, collecting evidence through methods such as  observation, document review, and interviews. Steps in an inspection  may include an opening conference, a walkaround by inspectors, worker  interviews, and a closing conference. Based on evidence developed  during the inspection, OSHA evaluates whether the employer has violated  any safety or health standards. The inspection may result in issuance of a  citation if appropriate, and possible appeals by the employer (see fig. 3). Although OSHA does not fine federal agencies, it does monitor these  agencies and conducts federal workplace inspections in response to  workers’ reports of hazards. Since workers at meat and poultry plants  include both plant employees and FSIS employees, OSHA officials may  inspect FSIS, the plant employer, or both when it receives a complaint or  referral about hazards at the plant. OSHA conducts both programmed and unprogrammed inspections.  Programmed inspections are planned based on injury incidence rates,  previous citation history, or random selection. For example, OSHA’s  emphasis programs focus inspections on a particular safety or health  hazard or a specific industry. Unprogrammed inspections are conducted  in response to imminent danger, fatalities, worker complaints, referrals,  and catastrophic events (such as hospitalizations). FSIS inspects each meat and poultry carcass at the majority of meat and  poultry plants throughout the United States. The Federal Meat Inspection  Act and the Poultry Products Inspection Act give FSIS responsibility for  ensuring the safety and wholesomeness of meat and poultry that enter  interstate commerce. As a federal employer, FSIS is also required to  establish and maintain a comprehensive and effective occupational safety  and health program for its employees that is consistent with OSHA’s  standards. However, OSHA (or a state agency in a state-plan state) is  responsible for overseeing the safety and health of non-federal plant  workers. FSIS’s Environmental, Safety, and Health Group administers  FSIS’s occupational safety and health program and investigates safety  concerns of FSIS inspectors. Within the Department of Health and Human Services, NIOSH conducts  occupational safety and health research and workplace evaluations, and  makes recommendations to prevent worker injuries and illnesses. In  2016, we reviewed NIOSH evaluations on hazards in the meat and  poultry industry such as those associated with musculoskeletal disorders  (MSD), chemical exposure, and pathogens and animals, and  recommended in our report that NIOSH conduct a study of the injuries  and illnesses experienced by meat and poultry sanitation workers. In 1994, after a workplace fire in 1991 that killed 25 poultry workers in  North Carolina, OSHA and FSIS signed an MOU on how the two  agencies could work together on worker safety and health at meat and  poultry plants. The MOU outlines the policies and procedures the  agencies agreed to use, including a process for FSIS to refer serious  hazards to OSHA, plans for OSHA and FSIS to develop and implement  training on hazard recognition for FSIS staff, an agreement to coordinate  on the development of standards and share information on common  concerns, and plans for evaluating implementation of the MOU. Federal Role in Chemical  Safety at Meat and Poultry  Plants Meat and poultry plants use chemicals such as antimicrobials to reduce  potential contamination on food and machinery during processing.  Antimicrobials may be sprayed directly on meat or poultry, or may be  used to clean machinery. FSIS officials and worker advocates have  raised worker safety concerns about peracetic acid, an antimicrobial  chemical that is being used by the meat and poultry industry for both of  these purposes. Peracetic acid has recently become the antimicrobial of  choice, according to an FSIS official and a representative from an  advocacy group. An FSIS official told us that this was because it is cheap  and effective at reducing potential contamination on food. In addition, it is  safe to use on food because it generally degrades before consumption,  according to FDA officials. FDA, FSIS, EPA, and OSHA all play a role in regulating the use of  chemicals at meat and poultry plants. Under the Federal Food, Drug, and  Cosmetic Act (FFDCA), as amended, FDA approves food additives,  which include antimicrobial food additives, to ensure the food to which  they are applied is safe for human consumption. Antimicrobial food  additives such as peracetic acid are applied to meat or poultry to reduce  the incidence of human illness from food-borne pathogens, such as  Salmonella and Campylobacter. FSIS reviews new ingredients and new technology, including new  substances or new applications of substances, to determine whether they  are safe and suitable for use in meat and poultry products. FSIS’s  review includes an assessment of whether the substance could affect  food safety, FSIS regulations, inspection procedures, or the safety or  health of FSIS inspection personnel. FSIS coordinates its reviews of  new ingredients with FDA’s reviews, in accordance with an MOU between  FSIS and FDA, most recently amended in January 2000. EPA is responsible for regulating chemicals that meet the definition of a  pesticide under the FFDCA and the Federal Insecticide, Fungicide, and  Rodenticide Act (FIFRA), as amended. Peracetic acid meets the  definition of an “antimicrobial pesticide” regulated by EPA when it is used  to disinfect, sanitize, or inhibit the growth of microorganisms on surfaces  and machinery used in meat and poultry plants. OSHA may regulate the use of chemicals as part of its responsibility for  overseeing workplace safety and health. For example, the hazard  communication standard requires chemical manufacturers and importers  to develop Safety Data Sheets that describe the chemicals’ hazards and  include information on safe handling, among other things. The standard  also requires employers to ensure their employees have access to these  sheets and to provide training on handling these chemicals  appropriately. Each agency has a different review or oversight responsibility. The same  chemical may undergo different types of review, depending on its  intended use in meat or poultry plants. For example, as part of EPA’s  pesticide registration process, EPA conducts risk assessments to  estimate the nature and probability of harmful effects on the environment  and human health, which may include people who may be exposed to the  pesticides through their work. FDA’s review of antimicrobial food  additives, as mentioned above, focuses on safety to consumers, and  does not include a worker safety component. OSHA Increased  Meat and Poultry  Industry Inspections  Since 2005, but  Faces Challenges  Identifying Worker  Concerns OSHA Increased Its  Annual Inspections Since  2005 and Provided  Compliance Assistance Inspections OSHA’s inspections of the meat and poultry slaughter and processing  industry increased from 177 in 2005 to 244 in 2016, due primarily to an  increase in poultry inspections (see fig. 4). Officials explained that the  increase in meat inspections from 2009 to 2010 and poultry inspections  from 2008 to 2012 were associated with increases in complaints during  those time periods. OSHA officials said that all inspections decreased in  2013 partly due to the federal government shutdown that year. They  added that poultry inspections increased from 2013 to 2016, which  officials attributed to the introduction of new severe injury reporting  requirements, as well as several emphasis programs focusing inspections  on the poultry industry. OSHA consistently conducted more meat than  poultry inspections, due to the greater number of meat plants than  poultry, according to OSHA officials. In states with state OSH plans, inspection numbers increased from 183  inspections in 2005 to 212 in 2016, due primarily to an increase in meat  inspections (see fig. 5). State-plan states conducted almost three times  as many total meat inspections as poultry from 2005 through 2016. The  number of state poultry inspections has remained steady over the time  period, in contrast with the increase seen in federal OSHA poultry  inspections. OSHA officials said they did not believe there is an  overarching explanation for the trend in state-plan state inspections,  because each state plan is independently run, and added that publicly  available data show the increase in meat inspections from 2008 to 2010  could have been driven by a large increase in programmed inspections  conducted by state-plan states during that time, along with increases in  several types of unprogrammed inspections in 2010. in the meat and poultry industry. These programs instruct inspectors to  investigate potential hazards such as chemical exposure, noise, and  ergonomic hazards. Two of the four programs also focus on issues such  as bathroom access, temperature of the plant, and employer recording of  injuries and illnesses, to check for recordkeeping violations. OSHA  inspections incorporated three of these emphasis programs in 2016; the  remaining program did not have inspections that year. OSHA’s most  frequently used national and regional emphasis programs in meat and  poultry plants in 2016 are shown below (see fig. 6). failing to inspect and test equipment  failing to investigate an ammonia leak,  and to investigate ammonia vapor  releases from pipes and valves within 48  hours  without input from at least one employee  having experience and knowledge  specific to the process being evaluated,  and failing to ensure the findings of the  process hazard analysis were resolved in  a timely manner and actions documented  failing to provide workers with an  appropriate respirator for chlorine and  sodium hydroxide releases  failing to provide workers adequate  training and information regarding the  hazards of  ammonia  lack of control procedures to protect  workers from electrical hazards and being  struck or caught by machine parts exposing employees to trip hazards and  potential electrical hazards by obstructing  passageways  failing to conduct fire, chemical release,  and extreme weather evacuation drills. OSHA initiates unprogrammed inspections in response to required  employer reporting of fatalities or severe injuries and complaints or  referrals from sources such as employees, union representatives, media  reports, or others. Unprogrammed inspections may include issues  covered by a relevant emphasis program as well. OSHA’s unprogrammed  inspections of the meat and poultry industry recently increased sharply— from 95 in 2014 to 210 in 2015—mainly due to the new severe injury  reporting requirements (see fig. 7). According to agency officials, OSHA  decreased the number of planned programmed inspections in order to  reallocate resources as the number of unprogrammed inspections  increased. If OSHA determines that a meat or poultry plant has violated a workplace  safety or health standard, it may cite the plant, specifying which standard  or standards were violated (see fig. 8). The most frequently cited standard  for employers in the meat and poultry industry, the control of hazardous  energy (lockout/tagout), relates to safely shutting down a machine, and  ensuring it remains shut off, while the machine is being serviced. OSHA  inspects safety controls related to this standard as part of its emphasis  program for amputations. In cases where an applicable standard does not exist, OSHA may use the  general duty clause of the OSH Act to cite a plant for exposing its  employees to a hazard. For example, OSHA does not have a specific  standard related to ergonomic hazards, which may cause MSDs.  Workers we interviewed in all five states said they frequently experience  pain related to postures or movements, and medical experts we  interviewed said that meat and poultry workers experience high rates of  MSDs. Citing the general duty clause can be challenging and resource  intensive due to the high burden of proof necessary to establish each  element of the violation, such as the difficulty in showing that work  hazards caused an injury, according to OSHA officials. In 2016, OSHA proposed initial meat and poultry plant penalties with a  median of $7,000 and assessed final penalties with a median of $4,900  for inspections where violations were found (see fig. 9). Proposed  penalties may be reduced after employers contest them before an  administrative law judge, or as a result of negotiating penalty amounts  with OSHA through an informal settlement process. A representative of  one worker advocacy group we interviewed said lowering penalties  weakens OSHA’s deterrence capabilities. OSHA officials and one worker  advocate said that allowing companies to negotiate lower penalties can  benefit workers because it may result in companies agreeing to create  safety programs or finding other solutions that improve worker safety.  One OSHA official said that citations may affect a company’s workers’  compensation insurance rate, magnifying the financial impact of the  violation. According to OSHA officials, initial and final penalties  increased in 2010 due to administrative adjustments that had the effect of  raising penalties on average. We previously reported that, according to an  OSHA official, OSHA increased penalties in 2010 after it determined that  penalties were too low to deter employer violations. In addition, officials  said that a few large penalties raised average penalties in 2010-2013. OSHA compliance assistance efforts during the years 2005-2016  included worker outreach through local foreign consulates, support for  training meat and poultry workers, administering employer recognition  programs, and supporting state consultation programs that provide  technical assistance to small and medium-sized businesses. OSHA has  not comprehensively tracked its compliance assistance activities in the  past, but officials told us the agency launched a database module that  started tracking these activities in fiscal year 2017. Recent examples of  OSHA’s compliance assistance efforts related to meat and poultry plants  include the following: OSHA officials stated that in fiscal years 2011-2015, states provided  558 on-site consultation visits, largely funded by OSHA, to small and  medium-sized meat and poultry plants. The visits provide confidential  safety and occupational health advice to small and medium-sized  businesses in all states across the country, according to OSHA, with  priority given to high-hazard worksites. These on-site consultation  programs, at no cost to employers, work with employers to develop or  maintain injury and illness prevention programs, which included  assisting employers on identifying potential hazards to prevent  injuries, according to OSHA officials. OSHA officials stated that, as of July 2016, six meat and poultry  plants were participating in the Safety and Health Achievement  Recognition Program, which recognizes small and medium-sized  businesses that have used OSHA's on-site consultation program  services and operate an exemplary injury and illness prevention  program, according to OSHA officials. OSHA officials stated that, as of July 2016, eleven meat and poultry  plants participated in OSHA’s Voluntary Protection Programs (VPP),  which aim to recognize employers that implement effective safety and  health management systems and maintain worker injury and illness  rates below average for their industry. OSHA has published guidance and other resources related to safety  and health in the meat and poultry industry, such as a 2013  publication on preventing musculoskeletal injuries in poultry  processing, and a poultry processing safety and health topics web  page. OSHA provided grants for worker safety and health education to  nonprofit organizations through the Susan Harwood Training Grant  Program. These grants target underserved or low-literacy workers and  workers in high-hazard industries. For example, in fiscal year 2016,  OSHA awarded a grant to the Western North Carolina Workers  Center to train poultry workers on topics including personal protective  equipment, hazard mapping, ergonomics, and sanitation worker  safety. OSHA officials stated that the agency conducted outreach with poultry  industry representatives to discuss common hazards, such as MSDs  and infectious pathogens, among others. For example, according to  OSHA officials, in support of a Regional Emphasis Program on poultry  processing, OSHA’s Dallas Regional Office conducted workshops in  the southwestern United States in December 2015 to share safety  and health information with employers in the poultry processing  industry. OSHA worked with groups such as unions, trade or professional  organizations, and educational institutions through its Alliance  program to develop compliance assistance tools and share  information with employers and workers to help prevent injuries,  illnesses, and fatalities in the workplace. For example, OSHA officials  said that the agency has formed alliances with foreign consulates to  reach workers with limited English proficiency. Also, OSHA’s Omaha  Area Office has an alliance with local organizations to help protect  workers in the meat packing industry. OSHA Faces Challenges  Identifying Worker  Concerns, Responding to  Medical Mismanagement,  and Gaining Entry to  Some Plants Identifying Worker Concerns OSHA faces challenges identifying and addressing meat and poultry  worker safety and health concerns because workers may be reluctant to  speak with inspectors, according to workers we interviewed in four states,  as well as worker advocates. Workers we interviewed in four states said  they fear dismissal or other punishment if they complain to OSHA or their  state OSH agency about their workplace concerns, such as sustaining  injuries or being discouraged from using the bathroom. We reported in  2016 that meat and poultry worker vulnerability may hinder reporting of  work-related illnesses and injuries, according to federal officials and  worker advocacy groups. In particular, these officials and advocates said  that some meat and poultry workers may be less likely to report or seek  treatment for injuries and illnesses because of their vulnerable status as  undocumented or foreign-born workers and because of their economic  vulnerability. Meat and poultry workers may also be reluctant to share information with  OSHA at their workplace, as on-site interviews often do not allow workers  to remain anonymous, even when conducted in private, according to  workers in one state, as well as worker advocates we interviewed.  According to OSHA officials, OSHA generally conducts worker interviews  on-site during inspections. Officials added that, when OSHA conducts on- site interviews, inspectors tell plant supervisors which workers they wish  to speak with, so the supervisors can find replacements for these workers  on the production line. Therefore, the supervisor knows the identities of  interviewed workers, even if the interview itself is private. Officials added  that if workers cannot be pulled from the line, they are sometimes  interviewed in front of other workers as they continue working. The OSH  Act prohibits employers from retaliating against employees for filing  complaints with OSHA. However, OSHA officials, workers from two  states, and worker advocates we spoke with noted that workers may feel  more comfortable sharing concerns about hazards if they are interviewed  off-site. The OSHA Field Operations Manual, which sets forth OSHA’s  enforcement policies and procedures, allows inspectors to interview  workers in locations other than the workplace, and states that, “a free and  open exchange of information between OSHA inspectors and employees  is essential to effective inspections.” OSHA’s performance goals in  DOL’s Strategic Plan include preventing discrimination against workers  who report hazards. According to OSHA officials, they will try to  schedule an interview off-site if an employee expresses discomfort or if a  union arranges it. Officials stated that they do not automatically offer off- site interviews to each employee; rather, inspectors should consult with  their Area Directors before offering to conduct an interview off-site.  However, OSHA officials told us that inspectors interview meat and  poultry workers off-site infrequently, since off-site interviews can be  challenging and take additional time, as workers may be difficult to  contact or may have ceased working with the company.  OSHA also may  be challenged to find an acceptable venue when the employee is  available. They added that conducting interviews off-site is more feasible  in cases when unions or worker advocacy groups have facilitated these  meetings, and that interviewing workers on the production line may be  advantageous in some cases, as it allows workers to clarify some  uncertainties by showing the inspector how their work is done. According  to federal internal control standards, agencies should use quality  information to achieve their objectives. Although OSHA officials stated  that OSHA has taken steps to enable the collection of quality information  from workers, such as conducting a representative number of interviews  and refraining from reporting information from specific interviews to  employers, officials acknowledged that some workers may feel more  comfortable sharing concerns about hazards if they are interviewed off- site. Taking additional steps to encourage workers to disclose sensitive  concerns, such as by considering off-site interviews or exploring other  options to obtain the information anonymously, would help OSHA learn  details about hazards, injuries, and illnesses during an inspection and  provide additional information to help improve the agency’s efforts to  identify or address conditions that endanger worker safety and health. In particular, OSHA may not be aware of the scope of bathroom access  issues, which meat and poultry workers we interviewed in all five states  said was a concern, because the agency’s reliance on interviewing  workers on-site may cause it to miss concerns of workers who are afraid  to speak up. In addition, OSHA inspectors do not always ask specifically  about bathroom access, and workers who experience bathroom access  problems may not volunteer this information. OSHA’s sanitation standard  provides that “toilet facilities, in toilet rooms separate for each sex, shall  be provided in all places of employment,” based on the number of  employees of each sex. According to OSHA guidance, this standard requires employers to make toilet facilities available so that employees  can use them when they need to, and may not impose unreasonable  restrictions on employee use of the facilities. OSHA guidance also  states that denial or delay of bathroom access can result in various  serious health effects, such as urinary tract infections, constipation,  abdominal pain, and hemorrhoids. Meat and poultry workers may be denied timely bathroom breaks  because they work in an assembly line environment, which generally  requires workers to be replaced if they leave their station. Workers we  interviewed in all five states said their requests to use the bathroom are  often delayed or denied, and workers in two states said they fear  punishment if they ask to use the bathroom too frequently or complain  about lack of bathroom access to their supervisors or to OSHA. Worker  advocates we spoke with reported hearing similar concerns on a frequent  basis and four worker advocacy groups in different regions of the country  reported concerns related to the timeliness of workers’ access to  bathrooms based on non-generalizable interviews of poultry workers.  For example, workers we interviewed in three states said they had  suffered negative health effects, such as kidney problems, from delayed  or denied bathroom breaks. One worker said she refrained from eating or  drinking until she had completed her shift, to avoid needing a bathroom  break. Also, workers we interviewed in all five states said that long lines  at the bathroom further limited bathroom access. Meat and poultry industry representatives we interviewed said that  bathroom access is not a problem because companies provide bathroom  access when needed. They said companies take different approaches to  ensuring bathroom access, such as having a supervisor fill in for a worker  who leaves the line, establishing scheduled breaks, or allowing workers to  leave the line as needed, even without a replacement. However,  according to worker advocates, supervisors may vary in implementing  plant policy and may feel pressure to fulfill production quotas. One  industry representative told us they believe some supervisors in meat and  poultry plants deny bathroom access in order to maximize production  output. OSHA officials said they did not believe lack of bathroom access was a  widespread problem in the meat and poultry industry. However, OSHA  officials said they have not compared bathroom access practices in the  meat and poultry industry with other industries involving moving  production lines because they vary by establishment even within a single  industry. OSHA issued a citation in March 2016 to a meat plant related to  bathroom access, although that citation is currently being contested by  the employer, and is pending as of September 15, 2017, according to  officials. From 2005 through 2016, OSHA issued three additional citations  to meat and poultry plants related to bathroom access; however, these  citations were withdrawn after the employers reached formal or informal  settlements with OSHA. OSHA guidance for inspecting poultry plants  allows inspectors to ask specifically about bathroom access when there  are complaints about it or prior problems, or in the context of specific  regional emphasis programs, such as the poultry emphasis program in  the southeast United States. In addition, OSHA’s poultry processing  regional emphasis programs in regions IV and VI require the inspector to  assess the adequacy of toilet and sanitary facilities, and of worker access  to them. If there are no prior complaints or relevant emphasis programs,  OSHA officials said inspectors ask workers about any other concerns, but  do not always specifically ask about bathroom access. Officials said that  requiring inspectors to investigate bathroom access would divert  inspectors’ limited resources from higher-priority hazards and could result  in companies’ claiming that the line of questioning is unsubstantiated.  OSHA requires inspectors at poultry plants to consistently investigate  other specific hazards, such as ergonomics hazards. According to OSHA  officials, the agency selected these hazards based on prior inspection  and illness and injury data showing the hazards to be widespread in the  industry. Officials contrasted these with the small number of citations  issued related to bathroom access. However, given that workers whom we asked about bathroom access  during off-site interviews in all five states said that bathroom access is a  problem, and worker advocates we interviewed stated it was as well, it is  possible that OSHA is missing instances of this hazard, resulting in  incomplete data to guide its inspections. According to federal internal  control standards, managers should use quality information to achieve the  agency’s objectives. While officials stated they believe that inspectors’  open-ended questions will prompt workers to share any concerns they  have with bathroom access, workers may not volunteer this information  unless specifically asked. For example, workers may not be aware that  they have the right to access bathrooms and so may not realize that such  information would be of interest to OSHA, according to one worker  advocate we interviewed. Gathering additional information about whether  meat and poultry workers experience delayed or denied access to  bathrooms could help OSHA determine the extent of the problem and be  better positioned to protect worker safety and health. Addressing Medical  Mismanagement at Plant  Health Units OSHA officials told us that addressing medical mismanagement at meat  and poultry plants is challenging because of the complex issues involved  and OSHA’s limited oversight of plants’ health unit staff. Specifically, they  said that ensuring proper certification for medical providers is the  responsibility of state authorities. In hazard alert letters to four meat and  poultry plants, OSHA noted its concern that plant health unit staff were or  may have been inappropriately supervised and working beyond the scope  of their medical license. Officials said OSHA contacted state authorities  who oversee health unit staff in one state about licensing concerns, and  they planned to contact additional states. OSHA officials we interviewed expressed concern about meat and poultry  workers’ access to plant first aid stations or health units and the quality of  medical treatment workers receive. OSHA issued one general duty  clause citation and four hazard alert letters to five meat and poultry plants  in 2015-2016 related to medical mismanagement issues, which describe OSHA’s findings or concerns about inappropriate medical treatment, lack  of worker access to health care, underqualified practitioners, and  challenges to reporting (see sidebar). In the citation, OSHA found that the plant delayed care for injured  workers, stating these actions could result in risk of further injury or  exacerbated pain, among other conditions. In a 2015 hazard alert letter to a poultry plant, OSHA noted that it  appeared the plant used its first aid station to prevent injuries from  appearing on the plant’s OSHA log, such as by failing to refer workers  to a physician for evaluation or treatment when appropriate. In  addition, OSHA noted that a number of workers were fired after  suffering MSDs, sometimes on the same day of the MSD occurrence,  and further noted workers’ fears of being fired for visiting the first aid  station. OSHA recommended voluntary improvements to the plant’s  medical management practices. In a 2014 hazard alert letter to another poultry plant, OSHA identified  practices that it determined were contrary to good medical practice for  managing work-related MSDs, including prolonged treatment by  nursing station staff without referral to a physician. The letter included  one example in which a worker made over 90 visits to the nursing  station before referral to a physician. Meat and poultry workers we interviewed in all five states reported  problems with on-site medical care; for example, workers said their  supervisor or plant nurse may not take appropriate steps when a worker  is injured or ill, such as not referring the worker to a doctor or failing to  move the worker to a different work station on the line. Worker advocates  we spoke with reported hearing similar concerns. One worker we  interviewed said that she experienced severe pain in her wrist and visited  the on-site medical unit over the course of 3 months before they referred  her to a doctor affiliated with the plant, during which time she continued to  work. When the doctor did not find any problems on her X-ray, she went  to a doctor unaffiliated with the plant, who found a bone fracture. Meat  and poultry workers in three states also said that fear of being  reprimanded or losing their jobs sometimes compels them to refrain from  accessing care at a plant health unit, or from complaining about  inadequate medical care. Workers in one state said they are penalized  every time they visit their plant health unit. Amputation Leads to OSHA Detection of  Medical Mismanagement and Other  Hazards  Following the amputation of a worker’s finger  at a poultry plant in 2016, the Occupational  Safety and Health Administration (OSHA)  conducted inspections and cited the plant for  violations related to: deficiencies with the procedures meant to  stressors as they performed tasks  requiring repetitive, forceful motion for  extended periods of time, often in  awkward positions  failure to comply with generally accepted  good engineering practices with respect  to exhaust systems, ammonia sensors,  and alarms, exposing workers to the  hazards posed by a potential ammonia  release  failure to provide free personal protective  equipment to workers  failure to repair or replace damaged  electrical equipment, exposing workers to  the risk of electrical shock. According to one industry representative, plants do not have enough  guidance on how to ensure their health units are properly staffed and  operated. OSHA issued guidance in 1999 about occupational health  professionals’ qualifications and scope of practice, as well as a 2006 best  practices guide on the fundamentals of a workplace first aid program.  However, OSHA officials told us these guidance documents do not  address many of the medical management issues they are currently  observing in plant health units, which include lack of supervision of  medical personnel, personnel working outside their scope of practice, out- of-date health unit protocols, inappropriate response to injuries and  illness, lack of quality assurance, poor worker access to health units, and  inadequate recordkeeping. OSHA officials told us that the agency has  recently begun updating its guidance related to health units to help clarify  employers’ responsibilities with regard to the personnel in these units and  the services they provide. However, these updates have not been  completed, according to officials. Federal internal control standards call  for agencies to externally communicate the information needed to achieve  their objectives. By updating and issuing its guidance, OSHA could help  plant health units be better positioned to provide appropriate care to  injured and ill workers. OSHA also issued hazard alert letters  recommending the plant take steps to address  the following hazards: medical management practices that  prevent appropriate standards of care,  increase the likelihood of workers  developing serious musculoskeletal  disorders, restrict referrals to physicians,  and discourage employees from reporting  symptoms and injuries. In some cases, plant management may deny entry to OSHA inspectors  attempting to conduct an inspection, and resolving these issues can  create delays. Although the OSH Act authorizes OSHA inspectors to  enter plants “without delay” at reasonable times to conduct inspections,  employers have the right to refuse entry, in which case OSHA may seek  an inspection warrant. If the employer denies entry after OSHA obtains  a warrant, OSHA determines its response on a case-by-case basis.  Denials of OSHA inspector entry to meat and poultry plants increased in  2016. All 15 denials in that year occurred in region IV, which includes the  Southeast United States. In contrast, from 2005-2015, there were 16  denials of entry in the meat and poultry industry. The denials in 2016 took  place in Georgia (6), Alabama (5), Florida (2) and Mississippi (2).  According to OSHA officials, the agency experienced denials in all 15  cases when it inspected a plant in response to a complaint or referral and  moved to expand the inspection to incorporate its regional emphasis  program for the poultry industry. OSHA has not been able to expand its  inspections in any of these cases, according to OSHA officials. These  denials of entry have the potential to limit OSHA’s understanding of  worker safety and health in plants during the days or months prior to  gaining entry, and addressing denials is resource-intensive, according to  OSHA officials. There is currently ongoing litigation in a case in which  OSHA was inspecting a plant after an employee was burned by an  electrical fire. OSHA attempted to expand the inspection under a relevant  emphasis program, and the plant contested the expansion in court. OSHA  officials said that the case is pending as of September 15, 2017, and they  will consider the outcome of the case when determining their response to  any similar denials of entry in the future. OSHA and FSIS  Have Not Fully  Implemented MOU  That Outlines  Collaboration on  Worker Safety and  Health OSHA and FSIS’s main vehicle for collaboration on worker safety and  health is their 1994 MOU, but efforts to implement and evaluate this  agreement have been limited. The MOU outlines the policies and  procedures the agencies agreed to use, including (1) a process for FSIS  to refer serious hazards facing plant workers or FSIS inspectors to OSHA,  (2) plans for OSHA and FSIS to develop and implement training for FSIS  staff in hazard recognition, and (3) an agreement to coordinate standards  development and exchange information on matters of common concern.  In 2005, we found that agency efforts to implement this MOU had lapsed,  and we recommended that OSHA and FSIS revisit and update certain  aspects of their MOU, as discussed below. OSHA and FSIS have taken  some steps to implement the policies and procedures outlined in the  MOU. However, we found issues with the MOU’s implementation in these  three areas, hampering achievement of the MOU’s goals. Further, OSHA  and FSIS have not evaluated the implementation of the MOU. Making Referrals to OSHA The 1994 MOU calls for FSIS inspectors—who may observe hazards to  both plant workers and inspectors—to refer serious workplace hazards to  OSHA, via FSIS headquarters. Serious hazards are defined in the MOU  as those for which there is a substantial probability that death or serious  physical harm could result. The two agencies have established a process  for these referrals, but according to FSIS officials its inspectors are  reluctant to make them, as discussed below. Until 2014, FSIS inspectors  were to refer these hazards to OSHA by sending a referral to OSHA via  FSIS headquarters, but, according to FSIS officials, inspectors rarely  made referrals under the former system. In 2014, FSIS established a  procedure for its inspectors to notify OSHA directly of serious workplace  hazards that may affect both FSIS inspectors and plant workers and  issued a notice that provides instructions for inspectors to use OSHA’s  nationwide public toll-free number to report such hazards. Because the  agencies are not able to track all of these referrals, as callers can remain  anonymous, it is not possible to assess the extent to which FSIS  inspectors are making them, according to OSHA officials. OSHA data  show that since 2012, OSHA had received 14 complaints and 2 referrals  about FSIS, of which 5 phone calls were from FSIS current or former  employees, but these data are likely incomplete. According to FSIS officials, its inspectors may be reluctant to make these  referrals because they fear it could trigger an OSHA inspection of FSIS.  As a federal employer, FSIS is responsible for ensuring its own  employees are protected from plant hazards, and is subject to OSHA  inspection and notification of safety and health hazards faced by its  employees. OSHA data show that from 2005 to 2016, OSHA inspected  FSIS in meat and poultry plants 105 times, of which 14 were in response  to complaints and referrals. FSIS occupational safety and health  specialists said these inspections can be a drain on their resources  because they are time-consuming and there are very few FSIS safety and  health specialists to respond to them. FSIS employs three occupational  safety and health specialists, along with one team lead, resulting in a ratio  of one specialist for every 3,100 employees, according to FSIS officials.  FSIS inspectors we contacted did not report communicating with OSHA,  and stated that they share any worker safety concerns they might have  with their management or with plant contacts. FSIS occupational safety  and health specialists told us that FSIS requests technical assistance  from OSHA to address hazards that may affect both plant workers and  FSIS inspectors. However, they said that OSHA may inspect FSIS  instead of providing assistance, even though OSHA has other ways of  offering technical assistance to federal agencies. For example, FSIS  occupational safety and health specialists told us that when they reached  out to OSHA for assistance with hazards posed by peracetic acid, OSHA  instead inspected FSIS for what FSIS considered to be unrelated  hazards. According to OSHA officials, their enforcement team is obligated to  respond to complaints and referrals, including calls to their toll-free  number, and may inspect FSIS if there is a report of a hazard at a meat or  poultry plant to which FSIS employees are exposed. OSHA officials noted  that FSIS employees should not be reluctant to report hazards because  OSHA inspections can protect FSIS workers. OSHA officials told us that  they are able to provide assistance with hazards if FSIS contacts OSHA’s  area offices, but if in the process, OSHA learns about a potential hazard  that is FSIS’s responsibility, then OSHA may investigate the agency.  FSIS officials told us they did not believe this process would ensure a  quick enough response by OSHA to provide FSIS assistance with urgent  hazards that could be harming FSIS inspectors and plant workers. Training FSIS Staff OSHA and FSIS agreed under the 1994 MOU to provide training to FSIS  inspectors so that they could recognize serious workplace hazards faced  by plant workers and FSIS inspectors. OSHA officials told us they  developed such training for FSIS in the mid to late 1990s, but according  to FSIS officials the course was too excessive and burdensome for FSIS  inspectors, whose main responsibility is food safety. In 2005, we  recommended that OSHA and FSIS revisit and update their MOU to  ensure that FSIS inspectors receive training in recognizing and referring  workplace hazards to OSHA. The two agencies did not update their MOU,  but FSIS officials told us the agency strengthened its training of FSIS  inspectors and OSHA officials told us that the agency planned to  cooperate with FSIS to encourage revitalization of FSIS’s inspector  training. According to FSIS officials, in 2013, FSIS began requiring its  inspectors whose duties were not limited to being on the line to take  AgLearn 8500, an FSIS course on identifying and reporting hazards that  was reviewed by OSHA. This course—which is now available only on  CD—is required for inspectors who do not work on the line and is optional  for those who do. In 2014, OSHA provided three training sessions on  identifying workplace hazards to FSIS managers, according to OSHA  officials. However, FSIS was not able to provide information on whether  or how the managers who received the training had shared what they  learned with FSIS inspectors because it did not track this information. Coordinating Standards  Development Line Speed  Meat and poultry slaughter and processing  generally occurs along a “disassembly line,”  on which workers and machines produce  various cuts of meat. These lines can include  live hang in poultry plants, evisceration lines,  and “cone” lines where deboning occurs. The  Food Safety and Inspection Service (FSIS)  sets maximum evisceration line speed in  order to ensure its inspectors can effectively  perform their inspection procedures.  According to FSIS officials, FSIS does not  regulate the speed of other lines, which may  run slower than evisceration lines due to  complex worker tasks. The Occupational  Safety and Health Administration (OSHA)— which is responsible for overseeing worker  safety and health—does not play a role in  regulating line speed, according to FSIS and  OSHA officials.  GAO reported in 2016 on concerns that high  line speeds may exacerbate existing hazards  that can cause musculoskeletal disorders  (MSD). OSHA and National Institute for  Occupational Safety and Health (NIOSH)  officials told us that line speed—in conjunction  with forceful exertions, awkward postures, and  other factors—affects the risk of MSDs. When  plants increase line speed, they may address  worker safety by increasing staffing or  creating new lines. speed may affect worker safety (see sidebar). FSIS officials told us that  OSHA provided comments after the proposed poultry modernization rule  was published in the Federal Register. According to the fall 2016 unified  regulatory agenda, FSIS is working on a proposed rule to amend the  federal meat inspection regulations to establish a new inspection system  for hog slaughter establishments. FSIS officials told us they consulted  with OSHA officials about the possible worker safety implications of the  proposed rule on hog slaughter prior to the rule being sent to OMB.  However, they also stated that—contrary to the OSHA officials cited  above—they believed the OMB review process was sufficient for  addressing any worker safety implications in rules proposed by FSIS. Evaluating the  Implementation of the  MOU FSIS and OSHA agreed to jointly evaluate the effectiveness and impact  of the actions taken under the MOU—in part by tracking the number of  FSIS referrals to OSHA, inspections made in response to these referrals,  and the number and types of hazards cited in these inspections—and to  make adjustments to the MOU as appropriate. According to FSIS and  OSHA officials we spoke with, this has not been done. Neither OSHA nor  FSIS was able to tell us why these evaluations did not take place. For  example, the MOU states that when training has been completed, OSHA  and FSIS will analyze field-level evaluations to assess whether the  training has raised FSIS inspectors’ awareness and reporting of serious  workplace hazards. OSHA officials said they do not know if FSIS used the  training materials they provided to FSIS to train FSIS field inspectors.  FSIS officials said the training OSHA provided was too time-consuming,  so they did not use it. Further, FSIS officials told us the agency does not  formally survey staff who complete AgLearn 8500 because it is available  only on CD. Our prior work has noted that developing mechanisms to  monitor, evaluate, and report results can help enhance and sustain  collaboration. Evaluating the implementation of the MOU and making  any needed changes, including setting specific timeframes for periodic  evaluations of actions taken under the MOU, would help ensure the goals  of collaboration are fully met. Gaps in Federal  Review, Safety  Information,  Measurement, and  Research May Put  Meat and Poultry  Workers at Risk of  Harm from Certain  Chemicals Federal Reviews of  Certain Chemicals Leave  Gaps Related to Plant  Worker Safety Federal reviews of certain antimicrobial chemicals before they are used in  meat and poultry plants leave gaps with respect to worker safety and  health. FSIS inspectors and workers in meat and poultry plants are  exposed to antimicrobial chemicals every day, as they are commonly  used during all work shifts, both on animal and bird carcasses and on  work surfaces and machinery. In general, the potential for chemical  exposure is greater for plant workers than for FSIS inspectors. According  to officials we spoke with at various plants, plant workers handle these  chemicals by receiving shipments, opening containers, and filling  machines with the chemical, among other ways, while FSIS inspectors  are generally not present at various times that workers are using the  chemical, most notably, when the plant is being cleaned between shifts. Depending on a chemical’s intended use, it may or may not undergo a  federal review of the risks it poses to worker safety and health before it is  used in the plant. The regulation of chemicals used in meat and poultry  plants is complex, as several federal agencies have their own specific  areas of jurisdiction with regard to their oversight. OSHA does not  conduct reviews of chemicals before they are used in the workplace,  according to OSHA officials. OSHA officials stated that the agency is  limited from taking such an approach, because doing so would  overwhelm the agency’s resources. In addition, OSHA is charged with  oversight of workers in multiple industries—not just the meat and poultry  industry—which would make it difficult for them to utilize a review process  that examines all chemicals before they are used in the workplace. Antimicrobial chemicals intended for use as sanitizers in plants to clean  machines and surfaces are generally subject to EPA’s pesticide  registration process, which considers user or worker safety (see fig. 10).  This review does not generally include antimicrobial chemicals applied  directly to meat and poultry in plants. When antimicrobials are proposed for use directly on meat or poultry to  combat foodborne pathogens, FDA and FSIS both conduct reviews  before they are used in the plant, but neither review specifically focuses  on plant worker safety or health. FDA’s review of antimicrobial food  additives is focused on ensuring they are safe for consumers to eat.  FSIS’s review is focused on ensuring that the antimicrobials do not affect  the safety of meat and poultry products or interfere with inspections and  that they comply with other FSIS regulations; it also includes an  assessment of any adverse effects on FSIS inspector safety and health  as they perform their duties. Since these federal reviews do not generally  take into consideration the occupational risk of chemicals to plant  workers, who make up the majority of personnel in a plant, these  chemicals could be used in plants directly on meat or poultry to combat  foodborne pathogens without a federal assessment of their potential  effects on plant worker safety and health or how these effects may be  prevented or addressed. As a result, plant workers may be put at risk of  chemical hazards. During its review of antimicrobial chemicals proposed for use directly on  meat or poultry, FSIS receives information from chemical manufacturers  that could be relevant to chemical safety for both FSIS plant-level officials  and meat and poultry workers. FSIS occupational safety and health  officials told us that the information they request goes beyond what is  included in the chemicals’ Safety Data Sheets, and may include directions  for use or safety information that is specific for dilution levels and  conditions of use at plants. However, this information is not shared with  OSHA, NIOSH, at the local level with FSIS in-plant inspectors, or with  plant management because FSIS does not have a process for doing so.  OSHA and FSIS occupational safety and health officials and an industry  representative we interviewed told us that this information would be useful  to them when it is available. OSHA officials told us that information on  chemical hazards, employee exposure, and safety controls and practices  would enable it to strengthen its response to protecting all workers from  these chemical hazards and develop outreach and technical assistance  for the meat and poultry industry. An FSIS safety and health official told us that this information would have  been useful at one plant, because neither plant management nor FSIS  inspectors at the plant had received information to adequately protect  FSIS employees from the effects of peracetic acid, and there had been  complaints from inspectors about the chemical. In addition, NIOSH  conducts occupational safety and health research, among other things,  and could benefit from such information. Federal internal control  standards call for agencies to internally and externally communicate the  necessary quality information to achieve the entity’s objectives. By FSIS  establishing a process to regularly share the worker safety information it  collects during reviews of new chemicals—internally with FSIS inspectors  and externally with plant management, OSHA, and NIOSH—the federal  government will be better positioned to use existing resources to support  the safety and health of plant workers and FSIS inspectors. Gaps in Inspector Safety  Information As discussed above, FSIS conducts reviews of new ingredients and  technologies, including antimicrobial chemicals, proposed for use on meat  and poultry products8. However, there may be information gaps in FSIS’s  examination of the potential risks these new chemicals may pose to  inspector safety and health. As part of this review, FSIS requests  information from chemical manufacturers or plants describing how the  new chemicals will not adversely affect the safety and health of FSIS  inspectors. As FSIS’s Environmental, Safety, and Health Group reviews  this information, other program areas within FSIS also review the  submission to determine whether the chemical is otherwise safe and  suitable under the conditions of its intended use—i.e., that it will not  adversely affect product safety, violate FSIS regulations, or interfere with  inspection procedures. If FSIS determines that the chemical will not have  these effects, the agency will issue a letter of “no objection” for the use of  the new chemical. It is unclear whether FSIS consistently reviews these chemicals to ensure  they will not adversely affect inspector safety and health because the  agency does not have a robust process for tracking and sharing  information needed to make this determination among the various  program areas within the agency participating in the review. Officials in  FSIS’s Environmental, Safety, and Health Group told us that they often  initially receive inadequate information to make this determination,  despite new guidance developed in 2015 on the type of information that  chemical manufacturers and plants may submit to enable FSIS to  evaluate potential adverse effects to inspector safety. In cases where  they do not receive sufficient information, the Environmental, Safety, and  Health Group will ask the FSIS program area that is leading the review to  request additional information from the manufacturer or plant. However,  FSIS does not have a process that seamlessly tracks the worker safety  information it receives as part of its review process, and FSIS  occupational safety and health officials told us it is not clear whether  submissions contain complete inspector safety information before a “no  objection” letter is issued. In response, other FSIS officials told us that  they would not approve a new chemical until they have adequate  information that shows it will not adversely affect the safety and health of  FSIS inspectors, among other things. Improving communication within FSIS about this review process is one  goal of FSIS’s 2017 Annual Plan. To help implement this goal, FSIS  formed a working group in April 2017 that is developing a draft directive to  facilitate improved coordination among the program areas involved in the  review process, including the Environmental, Safety, and Health Group.  More specifically, the draft directive provides procedures and protocols  and describes an electronic system for tracking information submitted.  According to FSIS officials coordinating reviews, the electronic system will  replace the current manual system and will be accessible to all program  areas involved in the review process. Further, the draft of a “no objection”  letter will be distributed to the program areas involved in the review to  ensure that all remaining outstanding questions or issues related to the  notification have been addressed prior to issuing the letter to the  submitter. According to an FSIS official, the agency plans to finalize and  issue the draft directive by the end of calendar year 2017 and anticipates  converting to the electronic tracking system in fiscal year 2018. Gaps in Measurement OSHA and FSIS officials told us that they have faced challenges  responding to complaints about air quality in meat and poultry plants,  because it is hard to measure airborne peracetic acid. According to  OSHA, FSIS, and NIOSH officials, there is no sufficiently reliable method  to measure peracetic acid in plants, in part because peracetic acid is not  stable and breaks down quickly. As a result, it is harder to assess the  extent of worker exposure to this chemical and plan for an appropriate  response. Some plants currently use monitors to sample for the  components of commercial peracetic acid (acetic acid and hydrogen  peroxide); however, the effects of peracetic acid exposure on workers can  be different than those caused by either of these individual chemicals or  by mixtures of peracetic acid with other chemicals. In 2013, OSHA’s Salt Lake Technical Center began working to develop a  validated sampling and analytical method that would permit measurement  of airborne peracetic acid with a high degree of confidence. Work on the  method continues, according to OSHA officials. NIOSH has begun  evaluating a range of commercially available peracetic acid monitors and  is planning to evaluate an air sampling method for peracetic acid.  The  lack of a reliable way to measure peracetic acid could also affect any  efforts by OSHA to develop a permissible exposure limit (PEL), a type of  workplace safety and health standard that officials said would enable the  agency to more easily cite employers for exposing their workers to  peracetic acid hazards, compared to using the general duty clause.  According to OSHA officials, the process for developing PELs is arduous,  and peracetic acid is one of many chemicals without such a limit or with  one that is outdated. In response to our 2012 report, which found  OSHA’s standard-setting process to be challenging and lengthy, OSHA  and NIOSH developed an MOU to support their research on developing  potential standards. Gaps in Peracetic Acid  Research In March 2017, NIOSH announced its intent to initiate a study of  workplace uses of and occupational exposure to peracetic acid, but this  study will not examine the safety and health hazards this chemical may  pose if it is combined with other chemicals, as can happen in slaughter  plants. The NIOSH study aims to develop an immediately dangerous to  life or health (IDLH) value and an effective workplace measurement  method, among other things. While the focus of this research is the  characterization of workplace exposure to peracetic acid, the study is not  intended to address the extent and consequences of mixing peracetic  acid with other substances, which can occur in several ways in meat and  poultry plants. As carcasses move from one stage of processing to  another, peracetic acid can come into contact with other substances,  such as when there are spills or in drainage systems. FSIS officials, a worker advocate, and plant workers we interviewed expressed concern  that the mixing of chemicals can create new safety and health risks for  workers. For example, an FSIS official said that an inspector at a poultry  plant complained about effects from airborne chemicals that appeared to  be related to the location of her work station, directly over a drain in which  multiple substances were pooling. In 2011, 152 workers at an Arkansas  poultry plant reported being hospitalized from effects of chlorine gas  created after a supervisor added sodium hypochlorite (bleach) into a  container holding a residual acidic antimicrobial solution, creating a  chemical reaction. NIOSH officials told us they are aware that chemicals can be used in  plants alongside peracetic acid and result in a mixed exposure, and that  this may be a serious problem. Although the focus of the current peracetic  acid study is primarily on the health effects of and exposures to peracetic  acid alone, NIOSH officials said that NIOSH has the capability to assist in  characterizing worker exposures of concern, and could consider such  research in a follow-on study, depending on available resources. In  addition, NIOSH officials told us that the agency will consider whether  potential health hazards exist from other chemicals in the environment,  particularly if they interfere with measuring peracetic acid exposures and  assessing health effects in workers. Moreover, officials told us that their  current study could provide the basis of follow-on research into other  workplace chemical hazards, including mixtures. In 2004, NIOSH recognized mixed exposures as a priority area for the  occupational safety and health research community and identified  significant gaps and research needs. According to the report, workers  from agriculture, construction, mining, and other industries are commonly  exposed to combinations of chemical substances, biological or physical  agents, and other stressors, and knowledge is limited regarding the  potential health effects of mixed exposures. Identifying these effects can  help characterize worker exposure and develop hazard controls that take  into account the components of the mixtures. According to NIOSH  officials, mixed exposures continue to be important to study because they  may represent a health hazard to workers, and employers should prevent or control workplace exposures to such mixtures. By considering the  addition to the agency’s research agenda of a proposal to examine  peracetic acid’s use in combination with other chemicals, NIOSH will be  better able to characterize worker exposure to such scenarios and  develop controls to reduce this hazard for workers. Conclusions While OSHA’s enforcement efforts in the meat and poultry industry have  increased since we reported in 2005, worker safety and health problems  persist and improvements are needed in identifying worker concerns,  strengthening federal collaboration, and protecting workers from certain  chemicals. Workers we spoke with reported they are reluctant to report  injuries, illnesses, and hazards because they fear losing their jobs. There  is a mismatch between concerns we heard from workers and the  problems reported by OSHA, particularly in the area of bathroom access.  Taking additional steps to encourage workers to disclose sensitive  concerns and gathering additional information to determine the scope of  bathroom access issues could enable OSHA to better identify worker  safety and health concerns. OSHA’s efforts to address medical  mismanagement at plants—which has resulted in poor medical care for  workers—could be improved by issuing updated guidance for employers  on how to manage their health units. Collaboration between OSHA and  FSIS is limited and has improved little since we recommended in 2005  that the two agencies strengthen their 1994 MOU on worker safety. Since  FSIS is already present in many plants, the federal government is missing  out on a cost-effective opportunity to further protect the safety and health  of both plant workers and FSIS inspectors by leveraging resources in this  fiscally constrained environment. Evaluating the implementation of the  MOU and making any needed changes would help ensure the agencies  improve their collaboration. With regard to chemicals, there are gaps in  information sharing and research that have heightened the risk of  chemical hazards for plant workers and FSIS inspectors. In particular,  FSIS collects information on how to protect its inspectors from new  chemicals, but it does not have a process to share this information with its  own inspectors, plant management, OSHA, or NIOSH. By FSIS  establishing a process to regularly share the worker safety information it  collects during reviews of new chemicals, the federal government will be  better positioned to use existing resources to support the safety and  health of plant workers and FSIS inspectors. Finally, NIOSH’s plan to  conduct a study on peracetic acid will likely yield useful information for  meat and poultry worker safety, but it is not intended to address the  potential consequences of mixing peracetic acid with other substances,  which can occur in several ways in meat and poultry plants. By  considering the addition to the agency’s research agenda of a proposal to  examine peracetic acid’s use in combination with other chemicals in meat  and poultry plants, NIOSH will be better able to characterize worker  exposure to such scenarios and develop controls to reduce this hazard  for workers. Recommendations for  Executive Action We are making seven recommendations, including four to OSHA, two to  FSIS, and one to NIOSH. Specifically:  The Assistant Secretary of Labor for Occupational Safety and Health  should take additional steps to encourage workers to disclose sensitive  concerns during OSHA inspections of meat and poultry plants; for  example, by considering additional off-site interviews or exploring other  options to obtain information anonymously. (Recommendation 1) The Assistant Secretary of Labor for Occupational Safety and Health  should gather more information, such as by asking workers during meat  and poultry plant inspections, to determine the extent to which bathroom  access is a problem and how to address any identified issues.  (Recommendation 2) The Assistant Secretary of Labor for Occupational Safety and Health  should update its guidance for employers on how to manage their health  units to address the challenges of managing these units.  (Recommendation 3) The Assistant Secretary of Labor for Occupational Safety and Health  should work with FSIS to assess the implementation of the MOU and  make any needed changes to ensure improved collaboration; and set  specific timeframes for periodic evaluations of the MOU.  (Recommendation 4) The FSIS Administrator should work with OSHA to assess the  implementation of the MOU and make any needed changes to ensure  improved collaboration; and set specific timeframes for periodic  evaluations of the MOU. (Recommendation 5) The FSIS Administrator should develop a process to regularly share the  worker safety information it collects during its review of new chemicals  with FSIS inspectors, plant management, OSHA, and NIOSH.  (Recommendation 6) The Director of NIOSH should consider including in the agency’s research  agenda a proposal for examining the extent of peracetic acid’s use in  combination with other chemicals in meat and poultry plants, and any  safety and health hazards these combinations may pose to workers.  (Recommendation 7) Agency Comments  and Our Evaluation We provided a draft of this report to the U.S. Department of Labor (DOL),  the U.S. Department of Agriculture (USDA), the U.S. Department of  Health and Human Services (HHS), and the Environmental Protection  Agency (EPA) for their review. DOL’s Occupational Safety and Health  Administration (OSHA), USDA’s Food Safety and Inspection Service  (FSIS), and HHS provided written comments that are reprinted in  appendixes II, III, and IV, respectively. In an e-mail dated October 5,  2017, an EPA audit liaison indicated that EPA had no comments. OSHA  did not state whether it concurred or not with the four recommendations  made to it. USDA expressed concern with the draft report’s  characterization of FSIS’s collaborative efforts and also described  planned actions to address the two recommendations we made to it. HHS  agreed with the one recommendation we made to it. DOL and HHS  provided technical comments, which we incorporated as appropriate. With respect to our first recommendation that OSHA take additional steps  to encourage workers to share information during meat and poultry  inspections, OSHA stated that it fully supports the idea of continuous  improvement of its processes that would expand its ability to identify and  address hazards before an injury, illness, or fatality occurs. However,  OSHA noted that it would be challenging to conduct offsite interviews in  terms of witness cooperation, resources, and inspector safety. We  continue to believe that OSHA should take steps to enhance reporting by  meat and poultry workers. Our report describes meat and poultry workers’  reluctance to report injuries, illnesses, and hazards to OSHA because of  their fear of employer retaliation. OSHA’s Field Operations Manual  highlights the importance of a free and open exchange of information  between OSHA inspectors and employees for conducting effective  inspections. Conducting additional offsite interviews is one way to  encourage employee reporting. However, there may be alternative  additional steps OSHA could take to better position it to encourage  workers to disclose sensitive concerns, consistent with our  recommendation. With respect to our second recommendation that OSHA gather additional  information to determine the extent to which bathroom access is a  problem in meat and poultry plants, OSHA stated it could not commit to  routinely asking about bathroom access at each meat and poultry  inspection. OSHA stated that each inspection requires a flexible approach  to address unique worksite hazards. It further stated that OSHA does not  routinely ask questions about any potential hazards that go beyond the  scope of a complaint inspection, unless those hazards are in plain sight.  However, as noted in the report, OSHA does require inspectors at poultry  plants to consistently investigate other specific hazards, such as  ergonomics hazards. Our report highlights the challenges meat and  poultry workers may face gaining timely access to bathrooms. However,  workers might not volunteer access information to OSHA. Our work  identified a mismatch between the concerns we heard from workers and  the problems reported by OSHA. Better understanding the scope of  bathroom access problems would better position OSHA to respond  appropriately. Further, OSHA may choose to address this issue without  routinely asking workers about bathroom access, such as by selectively  querying workers based on criteria determined by the agency. With respect to our third recommendation to update its guidance for  employers on management of plant health units, OSHA stated that it  intends to revisit its guidance. With respect to our fourth and fifth recommendations for OSHA and FSIS  to work together to assess the MOU’s implementation, make changes to  improve collaboration, and set timeframes for periodic evaluations of the  MOU, neither agency stated whether it agreed or not. OSHA stated that  meat and poultry plants provide an opportunity for the two agencies to  work collaboratively to identify employee hazards and promote safety and  health, but OSHA did not comment specifically on the recommendation.  FSIS stated that it already has directives in place to recognize and report  hazards affecting FSIS employees, and acknowledged that the MOU was  designed to additionally have FSIS employees report hazards affecting  plant employees due to the regular presence of its inspectors in plants.  FSIS noted that in collaborating with OSHA, FSIS will need to ensure its  primary mission is not compromised by undertaking activities that take  time and resources away from its food safety inspection responsibilities.  We continue to believe that strengthening the MOU and developing a  mechanism to regularly evaluate it would help ensure that the goals of the  MOU are met, and that leveraging FSIS’s presence in plants provides the  federal government with a cost-effective opportunity to protect worker  safety and health. With respect to our sixth recommendation that FSIS regularly share the  worker safety information it collects during its review of new chemicals  with FSIS inspectors, plant managers, OSHA, and National Institute for  Occupational Safety and Health (NIOSH), FSIS stated that the agency  already has a process for sharing chemical safety information with its  inspectors. However, FSIS has not provided us with evidence that it has  shared the worker safety information it collects related to new chemicals,  such as safety information that is specific for dilution levels and conditions  of use at plants, as noted in the report. FSIS also stated that it would take  certain steps to share information about approval of chemicals with other  agencies such as OSHA and NIOSH, but the steps identified did not  include sharing worker safety information. Incorporating worker safety  information would further help enhance this information sharing. FSIS  further stated that some of the information collected during its review of  new chemicals may be proprietary. In addition, FSIS also expressed concern with how we characterized its  collaboration with OSHA and NIOSH on worker safety. Specifically, in  reference to the report’s discussion of the development of the poultry  inspection modernization rule, FSIS stated that it consulted with and  included OSHA and NIOSH during the appropriate step of the rulemaking  process, and that the agency followed the Administrative Procedure Act in  proposing the rule. We do not intend to suggest any deficiencies with  FSIS’s rulemaking procedures. Rather, our report points out possible  opportunities for earlier and enhanced collaboration with OSHA on  standards development. FSIS also requested that GAO include  information in the report about the directive FSIS issued to implement the  annual attestation on work-related conditions required by the poultry  modernization final rule, and that the agency is sharing the information it  receives as part of this process with OSHA. We have incorporated this  information into the report. In its written comments, HHS agreed with our seventh recommendation  that it consider including in NIOSH’s research agenda a proposal for  examining the extent of peracetic acid’s use in combination with other  chemicals in meat and poultry plants, and any safety and health hazards  these combinations may pose to workers. As agreed with your office, unless you publicly announce the comments  of this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to the  appropriate congressional committees; the secretaries of Labor,  Agriculture, and Health and Human Services; and the Administrator of  EPA. In addition, the report is available at no charge on the GAO website  at http://www.gao.gov. If you or your staff have any questions about this report, please contact  me at (202) 512-7215 or brownbarnesc@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix V. Appendix I: Objectives, Scope, and  Methodology This report (1) describes the efforts the Occupational Safety and Health  Administration (OSHA) in the U.S. Department of Labor (DOL) has made  to help ensure meat and poultry workers’ safety and health, and assesses  what, if any, challenges OSHA faces in carrying out these efforts; (2)  examines how OSHA and the U.S. Department of Agriculture’s (USDA)  Food Safety and Inspection Service (FSIS) have collaborated to help  ensure meat and poultry worker safety and health; and (3) assesses any  factors that may affect OSHA and FSIS efforts to protect meat and poultry  workers from chemical hazards. The estimated total employment for the animal slaughtering and  processing industry in this report is an annual average calculated from  household data collected by the Current Population Survey (CPS) in  2016. The CPS is a probability sample and estimates derived from its  data have sampling errors associated with them. We followed the DOL  Bureau of Labor Statistics (BLS) technical guidance for estimating the  standard error of annual average totals from CPS data. We express our  confidence in the precision of our estimate as a 95 percent confidence  interval. This is the interval that would contain the actual population value  for 95 percent of the CPS samples that the U.S. Census Bureau could  have drawn. To describe injury and illness rates in the meat and poultry industry, we  analyzed and reported survey data from the BLS Survey of Occupational  Injuries and Illnesses (SOII) for calendar years 2004 through 2015 (the  most recent year for which data were available). The SOII provides  estimates of the number and frequency (incidence rates) of workplace  injuries and illnesses by industry and also by detailed case  circumstances, such as injury type and event, and worker characteristics  for cases that result in days away from work, based on data from logs  kept by employers (survey respondents)—private industry and state and  local governments. Survey respondents provide counts for all recordable  injuries and illnesses under OSHA recordkeeping regulations. To report SOII data from the meat and poultry industry (using North  American Industry Classification System (NAICS) code 31161 for the  animal slaughtering and processing industry), BLS provided estimates of  each industry’s injury and illness incidence rates and their associated  relative standard errors. All estimates produced from the analysis of the  SOII data are subject to sampling errors. We express our confidence in  the precision of the results as a 95 percent confidence interval. This is the  interval that would contain the actual population value for 95 percent of  the samples the respective agency could have drawn. For estimates  derived from BLS’s SOII data, we used the agency-provided relative  standard errors to estimate the associated confidence intervals. All  estimates we report have the associated 95 percent confidence interval  provided. To assess the reliability of BLS SOII data, we reviewed documents  related to the data sources, such as BLS’s Handbook of Methods, and we  interviewed agency officials knowledgeable about these data. We found  that SOII data were sufficiently reliable for our purposes in generally  reporting estimated incidence rates of injuries and illnesses in the meat  and poultry industry. To address all three objectives, we reviewed relevant federal laws and  regulations and interviewed officials from OSHA and FSIS. We also  visited four states—Arkansas, Georgia, Minnesota, and Texas—selected  based on factors such as high production of meat or poultry; regional  emphasis programs focusing on meat or poultry; presence of an OSHA  regional or area office; presence of industry and worker advocate  contacts; and access to meat or poultry plants participating in the  Voluntary Protection Program or the Safety and Health Achievement  Recognition Program. We used USDA statistics on the numbers of  cattle, hogs, chicken, and turkeys slaughtered annually in the United  States as a proxy for meat and poultry production for each state. As  appropriate for each site visit, we met with either local OSHA or state  Occupational Safety and Health (OSH) agency officials, as well as FSIS  officials (including inspectors, supervisors, and an occupational safety  and health official), industry representatives, experts in issues related to  worker safety, and representatives of worker advocacy groups; and we  visited four meat and poultry plants. At each plant, we met with plant  management, FSIS management and inspectors, and plant safety and  health staff, as available. The information gathered from these interviews  is not generalizable to all plants or meat or poultry workers. We also interviewed and reviewed information from additional  stakeholders, including experts in issues related to worker safety, as well  as representatives of worker advocacy groups. We identified and  interviewed these stakeholders based on previous work and on referrals  from other stakeholders. We also attended worker safety conferences  hosted by the meat industry, the poultry industry, and worker advocates. We also conducted group and individual interviews with meat and poultry  workers in six locations in five states: Arkansas, Delaware, Nebraska,  North Carolina, and Virginia. We interviewed between six and  approximately 30 workers per state, totaling approximately 72 workers  across all 5 interviews. We selected sites based on a variety of factors,  such as states with a relatively high level of meat or poultry slaughter,  according to USDA data; type of plant (meat or poultry); and geographic  diversity. We also considered resource availability and the ability of  supporting organizations to coordinate worker interviews. We coordinated  with worker advocacy groups or worker centers to identify meat and  poultry workers who were available and willing to meet with us. Interviews  were conducted in English or Spanish. The information gathered from  these interviews is not generalizable to all meat or poultry workers. To describe the efforts OSHA has made to help ensure meat and poultry  workers’ safety and health and assess any challenges, we reviewed  relevant documentation, such as agency guidance and information about  enforcement and compliance assistance activities. We interviewed  officials from OSHA and FSIS, as well as representatives of the meat and  poultry industry. We also analyzed enforcement data from calendar years  2005-2016 from two OSHA databases: the OSHA Information System  and OSHA Legacy Data. We examined data starting in 2005 because our  previous report on OSHA inspections in the meat and poultry industry  examined inspections data through 2004. We analyzed enforcement  data on federal and state inspections of meat and poultry plants, including  data on the type of inspection, violations found, standards cited, penalties  assessed, and whether inspectors were denied entry into the plant. To  analyze the number of inspections and the results of OSHA inspections of  meat and poultry plants, we analyzed inspections of plants with NAICS  codes 311611, 311612, and 311613 for meat plants, and NAICS code  311615 for poultry plants. To assess the reliability of the data, we  reviewed relevant agency documentation, conducted electronic data  testing, and interviewed agency officials knowledgeable about these data.  Based on these reviews, we determined that the data were sufficiently  reliable for our purposes. To assess OSHA’s efforts, we compared  information we learned to internal controls from Standards for Internal  Control in the Federal Government that call for agencies to use quality  information and to internally and externally communicate the necessary  quality information to achieve the entity’s objectives. To examine how OSHA and FSIS have collaborated to help ensure meat  and poultry worker safety and health, we reviewed relevant  documentation, such as information about OSHA’s and FSIS’s  collaborative activities, and we interviewed officials from OSHA and FSIS.  To analyze information on OSHA inspections of FSIS in meat and poultry  plants, we used the most recent data available for calendar years 2005- 2016 from the OSHA Information System and OSHA Legacy Data. We  also requested FSIS confirm which establishments pertained to the meat  and poultry industry. In assessing agency efforts, we reviewed the 1994  memorandum of understanding (MOU) agreed to by OSHA and FSIS,  and prior GAO reports that highlight interagency collaboration. We also  compared information we learned from officials to internal controls from  Standards for Internal Control in the Federal Government that call for  agencies to internally and externally communicate the necessary quality  information to achieve the entity’s objectives. To assess any factors that may affect OSHA and FSIS efforts to protect  meat and poultry workers from chemical hazards, we reviewed relevant  documentation, such as Environmental Protection Agency (EPA), Food  and Drug Administration (FDA), and FSIS processes for reviewing new  workplace chemicals, including FSIS’s Compliance Guideline Procedures  for New Technology Notifications and Protocols. We interviewed officials  from OSHA, EPA, FDA, and FSIS to understand how these reviews are  carried out and the extent to which agencies coordinate and share  information. We also interviewed representatives of the meat and poultry  industry. We compared information we learned from our review of  documents and interviews with officials to internal controls from  Standards for Internal Control in the Federal Government that call for  agencies to internally and externally communicate the necessary quality  information to achieve the entity’s objectives. To understand efforts  underway to develop tools to measure the presence of chemicals used in  plants, we reviewed scientific information on chemicals, such as peracetic  acid, and interviewed officials from OSHA’s Salt Lake Technical Center  regarding validated sampling and analytical methods. Focus shifted to peracetic acid during the course of our review because it  was identified by FSIS officials and worker advocates as a chemical  commonly used in plants for which OSHA had no permissible exposure  limit, and FSIS officials told us there were complaints the new chemical  was causing illnesses. We reviewed National Institute for Occupational  Safety and Health (NIOSH) health hazard evaluations to understand the  extent of concerns related to chemicals, including peracetic acid. To  identify any gaps in peracetic acid research, we reviewed documents,  including NIOSH’s 2017 Request for Information on peracetic acid, as  well as NIOSH’s research agenda and goals for studying the mixture of  chemicals, including its 2004 Mixed Exposures Research Agenda. We  also interviewed officials from NIOSH’s Education and Information  Division. We conducted this performance audit from May 2016 to November 2017  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives. Appendix II: Comments from the Department  of Labor Appendix III: Comments from the  Department of Agriculture Appendix IV: Comments from the  Department of Health and Human Services Appendix V: GAO Contact and Staff  Acknowledgments GAO Contact Staff  Acknowledgments In addition to the contact named above, Blake Ainsworth, (Assistant  Director), Mary Denigan-Macauley, Eve Weisberg (Analyst-in-Charge),  Rosemary Torres Lerma, Monika Gomez, Linda Collins, Erik Kjeldgaard,  Cathy Roark, Susan Aschoff, James Bennett, Almeta Spencer, Sarah  Cornetto, Monica Savoy, and Hiwotte Amare made significant  contributions to this report. Also contributing to this report were Ivelisse Aviles, Carl Barden, Tim  Bober, Kevin Bray, Marcia Crosse, John Mingus, Steve Morris, Ardith  Spence, and Mark Ward. Related GAO Products Workplace Safety and Health: Additional Data Needed to Address  Continued Hazards in the Meat and Poultry Industry. GAO-16-337.  Washington, D.C.: April 25, 2016. Regulatory Guidance Processes: Selected Departments Could  Strengthen Internal Control and Dissemination Practices. GAO-15-368.  Washington, D.C.: April 16, 2015. Chemical Assessments: Agencies Coordinate Activities, But Additional  Action Could Enhance Efforts. GAO-14-763. Washington, D.C.:  September 29, 2014. Food Safety: USDA Needs to Strengthen Its Approach to Protecting  Human Health from Pathogens in Poultry Products. GAO-14-744.  Washington, D.C.: September 30, 2014. Food Safety: More Disclosure and Data Needed to Clarify Impact of  Changes to Poultry and Hog Inspections. GAO-13-775. Washington,  D.C.: August 22, 2013. Workplace Safety and Health: OSHA Can Better Respond to State-Run  Programs Facing Challenges. GAO-13-320. Washington, D.C.: April 16,  2013. Workplace Safety and Health: Further Steps by OSHA Would Enhance  Monitoring of Enforcement and Effectiveness. GAO-13-61. Washington,  D.C.: January 24, 2013. Managing for Results: Key Considerations for Implementing Interagency  Collaborative Mechanisms. GAO-12-1022. Washington, D.C.: September  27, 2012. Workplace Safety and Health: Multiple Challenges Lengthen OSHA’s  Standard Setting. GAO-12-330. Washington, D.C.: April 2, 2012. Workplace Safety and Health: Better OSHA Guidance Needed on Safety  Incentive Programs. GAO-12-329. Washington, D.C.: April 9, 2012. Workplace Safety and Health: Enhancing OSHA’s Records Audit Process  Could Improve the Accuracy of Worker Injury and Illness Data.   GAO-10-10. Washington, D.C.: October 15, 2009. OSHA’s Voluntary Protection Programs: Improved Oversight and Controls  Would Better Ensure Program Quality. GAO-09-395. Washington, D.C.:  May 20, 2009. Whistleblower Protection Program: Better Data and Improved Oversight  Would Help Ensure Program Quality and Consistency. GAO-09-106.  Washington, D.C.: January 27, 2009. Workplace Safety and Health: OSHA Could Improve Federal Agencies’  Safety Programs with a More Strategic Approach to Its Oversight.   GAO-06-379. Washington, D.C.: April 21, 2006. Results-Oriented Government: Practices That Can Help Enhance and  Sustain Collaboration among Federal Agencies. GAO-06-15. Washington,  D.C.: October 21, 2005. Workplace Safety and Health: Safety in the Meat and Poultry Industry,  While Improving, Could Be Further Strengthened. GAO-05-96.  Washington, D.C.: January 12, 2005. Workplace Safety and Health: OSHA’s Voluntary Compliance Strategies  Show Promising Results, But Should Be Fully Evaluated before They Are  Expanded, GAO-04-378. Washington, D.C.: March 19, 2004. Workplace Safety and Health: OSHA Can Strengthen Enforcement  through Improved Program Management. GAO-03-45. Washington, D.C.:  November 22, 2002. Workplace Safety and Health: OSHA Should Strengthen the Management  of Its Consultation Program. GAO-02-60. Washington, D.C.: October 12,  2001. Food Safety: Weaknesses in Meat and Poultry Inspection Pilot Should Be  Addressed Before Implementation. GAO-02-59. Washington, D.C.:  December 17, 2001. Worker Protection: Better Coordination Can Improve Safety at Hazardous  Material Facilities. GAO-01-62. Washington, D.C.: October 26, 2000. Community Development: Changes in Nebraska’s and Iowa’s Counties  with Large Meatpacking Plant Workforces. GAO/RCED-98-62.  Washington, D.C.: February 27, 1998.
Meat and poultry slaughter and processing is one of the most hazardous industries in the United States. GAO was asked to review federal efforts to help ensure meat and poultry worker safety and health. This report (1) describes the efforts OSHA has made to help ensure worker safety and assesses any challenges to these efforts, (2) examines how OSHA and FSIS have collaborated to ensure worker safety, and (3) assesses factors that may affect OSHA and FSIS efforts to protect workers from chemical hazards. GAO analyzed OSHA inspection data from 2005—when GAO last reported on this issue—through 2016. GAO also interviewed OSHA staff in headquarters and six field offices; officials at four other federal agencies; worker advocates; and industry representatives. GAO visited four plants and interviewed workers at six sites in five states selected based on factors such as meat or poultry production. The Department of Labor's Occupational Safety and Health Administration (OSHA) increased its annual inspections of the meat and poultry industry from 177 in 2005 to 244 in 2016. OSHA officials told GAO that this increase was related to several new enforcement programs focusing on the poultry industry, as well as new reporting requirements that prompt additional inspections. However, OSHA faces challenges identifying and addressing worker safety concerns because workers may be reluctant to contact OSHA for fear of employer retaliation, although employers are prohibited from doing so by federal law. If workers are afraid to share concerns, OSHA may not be able to identify or address conditions that endanger them. In particular, OSHA may not be aware of the scope of problems workers could face gaining timely access to bathrooms. When asked by GAO, workers in five selected states cited bathroom access as a concern and said they fear speaking up at work, where OSHA inspectors typically interview them. Taking additional steps to encourage workers to disclose sensitive concerns and gathering additional information to determine the scope of bathroom access issues could enable OSHA to better identify worker safety and health concerns. OSHA's and the Department of Agriculture's Food Safety and Inspection Service's (FSIS) main vehicle for collaboration on worker safety is their 1994 memorandum of understanding (MOU), but efforts to implement and evaluate the MOU have been limited. The MOU outlines plans for collaboration, such as referrals of plant hazards to OSHA by FSIS inspectors, training of FSIS staff, and information sharing. OSHA and FSIS have taken some steps to implement the policies and procedures outlined in the MOU. However, GAO found issues with the MOU's implementation in these three areas, hampering achievement of the MOU's goals. For example, according to FSIS officials, FSIS inspectors may be reluctant to make referrals to OSHA about hazards in plants because they fear it could trigger an OSHA inspection of FSIS. Further, the agencies have not evaluated the implementation of the MOU. Evaluating the implementation of the MOU and making any needed changes would help ensure the goals of the MOU are met and further protect the safety and health of both plant workers and FSIS inspectors. Gaps in federal efforts create challenges to protecting workers from certain chemical hazards. For example, depending on a chemical's intended use, it may not undergo a federal review of the risks it poses to worker safety and health before it is used in a plant. FSIS collects information on how to protect its inspectors from new chemicals, but it does not have a process to share this information with OSHA or plants, among others, so that plant workers can be similarly protected. By FSIS establishing a process to regularly share the worker safety information it collects, the federal government will be better positioned to use existing resources to support the safety and health of plant workers and FSIS inspectors.