I can thank the Trump Administration for one thing. I now have a new phrase to describe how the poultry industry distorts information about working conditions for its employees: alternative facts.
Last fall, the National Chicken Council, National Turkey Federation and U.S. Poultry & Egg Association made a wild pronouncement about their industry’s work-related injury rate. They asserted their injury rates are at an all-time low and have declined by 81% since 1994. The trade associations’ news release said:
“Perhaps more than any other industry, the poultry industry has focused its energies on the prevention of workplace injuries and illnesses, especially musculoskeletal disorders like carpal tunnel syndrome, by recognizing the value of implementing ergonomics and medical intervention principles….”
A new paper published in the Journal of Safety Research explains why the industry’s assertion is a falsehood. It explains the ways in which some employers in the industry game the system so that injuries are not recorded on their logs.
The paper, “Under-recording of work-related injuries and illnesses: An OSHA priority,” was written by two physicians from OSHA’s Office of Occupational Medicine. The authors, Drs. Kathleen Fagan and Michael Hodgson, report findings from the agency’s special emphasis program which examined employer records of worker injuries. The findings include:
- 269 of the 405 establishments audited by federal OSHA (i.e., 66%) had injury recordkeeping violations.
- a large share of the violations involved unrecorded cases (cases not found on the employer’s log) and under-recorded cases (cases where days away or restricted work activity were not accurately recorded on the log). More than 47% of the establishments inspected had unrecorded and/or under-recorded cases.
Practices in the meat and poultry industry are particularly relevant to debunk their alternative facts. The audits in those plants found:
- “More than twice as many under-recorded errors per inspection compared to other sectors, due at least in part to the very poor recordkeeping practices of some establishments.”
The phrase “very poor recordkeeping” is non-judgmental. It doesn’t reflect motivation. I’m sure that’s something about which OSHA needs to be careful.
I, however, suspect it is something more intentional. Poultry companies with inaccurate injury records are engaged in a number of schemes to deny their employees are injured on the job. It’s the way the industry can claim an “81% decline in injury rates.” Several of the industry’s schemes are addressed in Fagan and Hodgson’s paper. For example, the authors characterized on-site medical units in poultry plants as
“a new obstacle to accurate recordkeeping.”
They note that some of these plant retain emergency medical technicians (EMTs) or licensed practical nurses (LPNs) to staff the medical units. Yet,
[the individuals] “…had little to no nursing or medical supervision, functioned without appropriate, up-to-date protocols and provided care beyond their scopes of practice.”
And the implications of that? The authors go on to explain:
“In some cases, workers were seen multiple times without referral for a definitive evaluation, diagnosis and treatment. By preventing access to higher level medical care, these cases were kept off the employer’s recordkeeping log.”
Here’s one example provided by the authors of how this plays out:
“Ms. S., a 40 year old Hispanic woman, had worked at the poultry plant for several years. She described symptoms of pain, numbness and tingling of both hands beginning one month after she started working on the debone line. She had no previous similar symptoms, no history of hand or wrist injuries or carpal tunnel syndrome, and no underlying medical problems.”
“When her symptoms did not go away, she reported to her supervisor, who brought her to the onsite nursing station. The nursing station was staffed by LPNs, who reported to the plant’s EMT-trained safety director. The LPNs were provided no higher level medical supervision by a physician, registered nurse or nurse practitioner. The LPNs treated Ms. S. with ice, muscle gel, Epsom salt soaks and non-steroidal anti-inflammatory medication (NSAIDs) for a ten-week period, seeing her a total of 94 times.”
“Ms. S. asked to see a doctor several times but was not referred and continued to be sent back to her regular job on the debone line. No assessment of the relationship between her job and her symptoms was performed, and her injury was not placed on the OSHA 300 log.”
The authors continue:
“After suffering worsening symptoms over two and one-half months and persistently requesting to see a doctor, Ms. S. was finally referred to the local physician. She was diagnosed with bilateral carpal tunnel syndrome and placed on work restrictions. Her clinical course included unsuccessful treatment with cortisone injections, permanent transfer off the debone line and plans for carpal tunnel release surgery.”
“…It is likely that, if Ms. S. had been removed from the debone line and referred to a physician earlier, she would not have suffered severe bilateral carpal tunnel syndrome resulting in chronic disability and requiring surgery.”
The authors repeat that these sort of medical management practices
“represent a significant newly-identified cause of under-reporting and under-recording.”
OSHA implemented its special emphasis program from September 2009 through February 2012. It did so in part because of criticism from the Government Accountability Office (GAO). GAO said OSHA had not focused adequate attention to the accuracy of the injury logs kept by employers. GAO noted that OSHA typically only audited 250 employer logs each year. Moreover, the audits were incomplete because inspectors relied primarily on information provided by the employers. GAO recommended that OSHA inspectors try to interview workers about injury and illness incidents about which they were familiar.
In “Under-recording of work-related injuries and illnesses: An OSHA priority,” the authors indicate that during the emphasis program, inspectors conducted over 4,800 employee interviews. Twenty percent of the unrecorded or under-recorded cases they identified came about because of the employee interviews.
Thanks to the OSHA inspectors and medical staff who helped to debunk the poultry industry’s “alternative facts.”