By Eric J. Conn and Samuel S. Rose

On October 15, 2024, OSHA issued Inspection Guidance for Animal Slaughtering and Processing Establishments that updates enforcement protocols for the agency’s field staff and compliance guidance for employers in NAICS Code 3116 (Animal Slaughtering and Processing), which includes NAICS Codes 311611 (Animal (except Poultry) Slaughtering), 311612 (Meat processed from carcasses), 311613 (Rendering and meat byproduct processing), and 311615 (Poultry processing).   The guidance takes the form of a memorandum from the Director of OSHA’s Directorate of Enforcement Programs out to all of OSHA’s Regional Offices.

OSHA justified the need for the updated enforcement guidance by noting that animal slaughtering and processing workers suffer serious injuries at a rate that is more than double that of all industries combined.

The updated OSHA guidance supersedes and replaces OSHA’s October 28, 2015 “Inspection Guidance for Poultry Slaughtering and Poultry Processing Establishments.”

The memorandum encourages each OSHA Region to determine whether a special enforcement emphasis program — either a Regional or Local Emphasis Program — is justified after reviewing relevant data in their regions. There are currently active emphasis programs in Region 4 (Regional Emphasis Program for Poultry Processing Facilities covering Georgia, Florida, North Carolina and South Carolina), Region 5 (Regional Emphasis Program for Food Manufacturing Industry covering Illinois, Ohio, Wisconsin, Michigan, Indiana, and Minnesota), Region 6 (Regional Emphasis Program for Poultry Processing Facilities covering Texas, Oklahoma, Arkansas, Louisiana, and New Mexico), and Region 7 (Nebraska Local Emphasis Program for Meat Processing Industries).  Because OSHA believes these hazards are pervasive nationwide, State OSH Plans, especially those with significant meat and poultry processing industries, are encouraged by OSHA in this enforcement memorandum to follow this guidance document.

Pursuant to OSHA’s updated memorandum, all programmed and unprogrammed inspections in NAICS 3116 will scrutinize Continue reading →