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Volume 9, Number 3, Fall 1997

Topics for this issue: ENVIRONMENTAL

U.S. Department of Labor takes an in-depth look at the poultry industry

EWAS helps ergonomic researchers gain new insight into cutting mechanics and injury risk

PoultryNet to debut in 1998

Poultry World draws record crowd at Georgia National Fair

Poultry plants advised to begin focusing attention on EPA’s Risk Management Program

Plan now to visit Georgia Tech at the 1998 International Poultry Exposition

 

U.S. Department of Labor takes an in-depth look at the poultry industry

In June 1997, the U.S. Department of Labor announced plans to conduct a focused study of the poultry industry’s compliance with labor regulations. Since this announcement, a series of briefings have been held and survey teams have visited a number of plant sites. While everyone anxiously awaits the study findings, this article details the events leading up to the plant visits and some of the controversy surrounding the study.
In what has been described by Department officials as a fact-finding effort, the U.S. Department of Labor has undertaken an in-depth review of the poultry industry to learn more about its performance relative to complying with Safety and Health and Wage and Hour regulations. Prompted by what many feel were focused criticisms of the industry by organized labor groups and a protracted enforcement action against a New England poultry concern, the study was formally announced in June by John Miles, Director of OSHA’s Compliance Programs, at the 1997 Safety Workshop for the Poultry Industry held in Atlanta.
In his June presentation, Miles emphasized this was not an “Enforcement Special Emphasis Program,” but rather an “Investigative Survey” designed to clear up any confusion that might exist relative to industry efforts to comply with labor standards. The survey, it was noted, would be carried out jointly by OSHA and the Wage and Hour Division of the Department of Labor using “consultation,” not “compliance” personnel.
Industry response
The industry was quick to respond, questioning the motivation behind the survey. They pointed out the strong commitment of the industry to a safe and productive workplace and stressed efforts over the past several years that have generated training materials, educational programs, and voluntary safety guidelines for use across the industry. Many argued that these efforts, along with the industry’s willing participation in OSHA partnership programs and its moderate injury statistics, simply did not add up to the need for a special Investigative Survey. The National Broiler Council further questioned the logic of tying up federal inspection resources for such a survey when they were needed to deal with legitimate compliance problems.
Survey Briefings
In July, Labor officials held meetings with the industry and special interest groups to discuss the survey further.
Late in August, the survey was officially kicked off with a letter and packet of materials announcing three September briefing sessions–one each in Baltimore, Atlanta, and Little Rock–to detail the purpose of the survey and to discuss the methodology to be used.
In the September briefings, Labor officials stated that they felt a more in-depth look at the industry was warranted by inconsistencies in reported industry safety data and concern over the recent rapid expansion of the industry and its reliance on relatively low-wage positions. The survey was designed to measure labor regulation compliance at specific worksites in the poultry processing industry in an attempt to establish a compliance baseline for the industry.
The survey, officials went on to state, would be carried out using site visitations. In all, approximately 174 plant locations had been targeted for possible visitation, from which a smaller, but significant, study sample would be actually chosen. Each site selected would be visited by a four-person inspection team made up of two Safety and Health members and two Wage and Hour members. In a switch from the June position, officials conceded “compliance” rather than “consultation” personnel would be used, primarily because of their experience in conducting plant inspections. OSHA representatives quickly stressed that despite the use of compliance personnel, the objective remained to collect data, not to conduct focused enforcement inspections. As such, inspection personnel would be instructed to initiate enforcement action only in situations of imminent danger, i.e. conditions potentially threatening life.
It was reported in the meeting that all targeted sites had been mailed a packet of information outlining provisions of the Fair Labor Standards Act, the Migrant and Seasonal Agricultural Workers Protection Act, and the Occupational Safety and Health Act, and listing the responsibilities and obligations of employers under these laws. Each site ultimately selected was told to expect an unannounced visit that would last from three to four days. Site visits were scheduled to begin on October 6 and be completed by November 1.
As of this writing, it has been reported that all site visitations are complete and collected survey data is currently being analyzed. The Department of Labor says that it plans to hold follow-up meetings when this analysis is finished to report its findings. These meetings will occur sometime after January 1, 1998.

 

EWAS helps ergonomic researchers gain new insight into cutting mechanics and injury risk

Georgia Tech engineers and scientists are breaking new ground in the field of ergonomic research. Using a newly redesigned Ergonomic Work Assessment System (EWAS), the study team has begun collecting cutting mechanics data on workers performing two different types of deboning cut: a wing cut and a tender cut. These data are already beginning to reveal quantifiable differences among workers performing the same cutting activity. This article addresses the significance of these preliminary findings and discusses the future directions for both this study and the EWAS system itself.
Breaking new ground in ergonomics, Georgia Tech researchers have initiated in-plant studies on worker cutting mechanics with the goal of trying to generate a better understanding of effective and safe cutting motions.
These studies are being carried out with help from a newly redesigned Ergonomic Work Assessment System (EWAS), which measures cutting forces, muscle exertion, and wrist position. EWAS provides a wealth of information about how muscles are called upon to perform tasks–information that can be used to boost efficiency on the factory floor and correct inefficient movements and awkward postures that may lead to injuries.
“ EWAS is a big step forward in helping quantify ergonomic activity,” says Robert J. Gregor, head of Georgia Tech’s Health and Performance Science Department and lead research scientist on the project. “Without it, ergonomists must use such subjective terms as ‘difficult’ or ‘easy’ to describe an activity. With it, we can assign numbers that reflect actual force and muscle exertion for that activity.”
Preliminary test results
Using three different plant locations, the research team has initially studied fifteen workers performing two different types of deboning cut: a wing cut and a tender cut. In all, forty trials have been conducted on each worker, twenty for each cutting activity. All trials have been carried out on the plant floor but not on the processing line. An off-line location was selected to prevent disruption of plant operations until the research team becomes more comfortable with EWAS.
Study results have revealed a wider range of cutting motion than was originally expected among different workers performing a similar cut. Range of motion, in this instance, refers to the angular movement of the wrist during the cutting process, in both the lateral and vertical directions. As the wrist angle increases from the neutral position, it begins to impact the efficiency of force transfer from the arm to the hand, thereby increasing the risk of possible injury. In the subjects studied, differences in angular wrist movement of up to 30 degrees were observed among subjects performing the same task.
Test results also revealed that considerably more cutting force is used to make a wing cut than a tender cut. Wing-cutting forces were observed that were as much as three times that of the tender-cutting forces for the same test subject. (See chart above.)
“ While these results are very preliminary, they clearly demonstrate the value of EWAS,” notes Craig Wyvill, Director of the Agricultural Technology Research Program which is funding the research effort. “Armed with such data, researchers can begin to evaluate the impact of training on narrowing worker range of motion and quantify the impact of such engineering interventions as modifying the knife to reduce cutting forces.”
But perhaps of even greater importance is that safety specialists in the industry see EWAS as an opportunity to provide feedback to the employee. “The on-line feedback of force, posture and muscular exertion, I believe, will allow employees to develop greater skills that both reduce physical stress and improve efficiency,” says Ron Jones, ergonomics manager at Gold Kist.
Future plans
The research team plans further field trials using EWAS between now and next June. In addition, Dr. Gregor is preparing a grant application to seek federal support for a more involved study of exertion and injury formation, with the goal of improving the ability of the industry to more systematically reduce cumulative trauma injuries across the board.
Although initially developed to study cutting activities in the poultry industry, EWAS has the potential to be used in the study of many other activities in a wide range of industries. Its sensors can be adapted to virtually any tool to study operations ranging from keyboard entry to heavy manual tasks.
“ Mobility is one of the major keys to EWAS’ versatility,” notes Dwight Waddell, a research engineer working on the study. Laboratory testing has its benefits, but there is also a downside. “Sometimes you’re so obtrusive when taking measurements that the task being examined is no longer realistic,” explains Waddell. “The next thing you know, you’re taking interesting data, but it really has nothing to do with what workers do everyday on the factory floor.”
To date, the research team is pleased with EWAS’ ability to capture data on the plant floor. In upcoming tests, they plan to take measurements on subjects working directly on the processing line. Long term, they believe EWAS can help to begin unraveling some of the mystery that continues to surround cumulative trauma injury in the poultry industry.

 

PoultryNet to debut in 1998

In late January 1998, PoultryNet is scheduled to go on-line. PoultryNet is an innovative, World Wide Web-based system designed to pipeline communications and information transfer within the poultry community. This article discusses some of the design issues faced by the development team in putting the system together and outlines their plans for initial system operation. It also explores plans for adding features to the system at a later date.
PoultryNet, an advanced Internet information center designed to provide easy access to poultry-specific resources any time, anywhere, is scheduled to make its debut in late January 1998. Utilizing state-of-the-art interactive technologies linked via public networks, PoultryNet is initially intended to pipeline communications and information transfer within Georgia’s vast poultry industry. Ultimately, it is expected to become a global reference point on the Internet for all poultry-related activities.
The ever-growing abundance of information available on the Internet is a problem for businesses trying to access online resources. Several commercial ventures have attempted to create a universal searchable index of the Internet; however, these “search engines” collect both useful and trivial information equally. Currently, no site exists which focuses solely on cataloging, indexing, and filtering information related to all aspects of the poultry business.
For example: a company having a problem with wastewater might launch a search for relevant information on the Internet. A recent search for “wastewater and poultry” returned over 35,000 possible matches. Industry users typically do not have the time to manually sort through such a list for relevant information. However, a visit to PoultryNet will produce a list of filtered documents, sorted by categories such as research reports, equipment suppliers, and consultants. PoultryNet will also contain an index of pertinent outside resources, which can be used to quickly and efficiently conduct a more refined, targeted web search. It will also contain links to sites containing copies of pertinent regulations, and will have a list of who in Georgia handles regulatory problems.
Key among the challenges that faced the PoultryNet design team was to build a system that could grow over time rather than remaining static. “We focused considerable attention on user interface issues, trying to focus on the problems a multiple audience creates,” notes Chris Thompson, PoultryNet project director. “This included focusing on technology options for ease of interactive exchange and security issues related to information exchanges of a sensitive nature.”
Users of PoultryNet will be able to perform a variety of interactive tasks: examine a calendar of upcoming events; view reports on previous special events such as the International Poultry Show; download working software tools to help with tasks such as water reduction audits; and subscribe to an electronic newsletter or internet channel of poultry-related news. Georgia PoultryNet users will also have access to a few specialized interactive features. For example, they’ll be able to request assistance from Georgia-based university service programs, search an electronic yellow pages of poultry personnel in Georgia, and discuss issues of concern with fellow industry members. Information related to poultry’s impact on the Georgia economy will also be available.
Although targeted primarily at industry users, PoultryNet will also have a section for the general public. This section will provide a searchable index of poultry recipes to which any viewer can add. Tips on preparation techniques and other safety information are also included. An ever-changing trivia quiz is included to test the knowledge of the viewer.
Future plans for PoultryNet include adding a feature to allow any research- or service-related organization in Georgia that deals with the poultry industry to add and update information about its operations. Eventually all participating parties will be able to add content to a tailored section designed specifically for their targeted audience. Craig Wyvill, Director of the Agricultural Research Program at Georgia Tech states, “ Our goal is to harness the power of the Internet for the exchange of useful information among everyone associated with this dynamic industry.”

 

Poultry World draws record crowd at Georgia National Fair

Poultry World, an educational exhibit highlighting Georgia’s poultry industry and its many innovations in delivering affordable, high-quality products, attracted a record crowd at the 1997 Georgia National Fair, held October 3-12 in Perry, Georgia. The exhibit, which won an international award for “Outstanding Special Event” in its first appearance at the fair in 1995, drew an estimated 40,000 people over the fair’s ten-day run this year. Half of those visiting the exhibit were school children, who toured the exhibit as part of the fair’s Georgia National School House Program.
“ Poultry World has become a community event for everyone associated with the industry here in Georgia,” notes Craig Wyvill, exhibit chairman. Over 150 volunteers from poultry companies, universities and government agencies, and allied industries across the state donated their time and energies to help make this exhibit a success. For many, it was a rare opportunity to step out of their normal routine and become spokespersons for the industry.
New features in the exhibit this year included an expanded hatching egg display (with 30 to 40 chicks hatching out each day) and a working copy of Poultry Plus, the educational CD-ROM about the poultry industry developed for middle and high school students.

 

Poultry plants advised to begin focusing attention on EPA’s Risk Management Program

With the compliance deadline for OSHA’s Process Safety Management Program (PSM), poultry plants are advised to begin focusing their attentions on EPA’s Risk Management Program (RMP) which goes into effect in June of 1999. While PSM addresses the on-site release of targeted chemicals, RMP addresses the off-site release of these same chemicals. This article addresses the links between PSM and RMP and also explains their differences. It outlines who has to comply with the upcoming regulation and the steps that must be taken to achieve compliance. Even though facilities have until 1999 to submit their plans, they need to begin working on them as soon as possible, since the analysis of off-site consequences can take more time to complete than many realize.
During the 1980s the United States Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) established a number of regulations designed to protect people and the environment. These regulations were in response to chemical accidents in the United States and abroad (such as the 1984 release of methyl isocyanate in Bhopal, India, which killed thousands of people).
Some of these regulations affect the poultry industry. For example, OSHA’s Process Safety Management (PSM) (specified in 29 CFR 1910.119) requires facilities storing certain amounts of chemicals to develop management plans to control and prevent on-site releases of these chemicals. (See PoultryTech Winter 1997 issue for more information.) Chemicals that affect the poultry industry are primarily ammonia and chlorine. If poultry processors have more than 10,000 pounds of ammonia in a refrigeration system or 1,500 pounds of chlorine for water disinfection stored on-site at any one time, then they must have a PSM program in place.
In 1990 when the EPA Clean Air Act was amended, section 112(r) established additional requirements related to the storage of chemicals–the Risk Management Program (RMP). The rules and lists of chemicals for RMP are published in EPA regulation 40 CFR 68. RMP works in conjunction with PSM. A facility is required to have either a PSM or RMP program, or both if it stores more than threshold quantities of certain chemicals on site (see table on threshold quantities of chemicals). While PSM addresses the on-site release of chemicals, the RMP addresses the off-site release of the chemicals. According to ATRP’s Jim Walsh, “Processors can use the prevention program plans they have in place for PSM to formulate an RMP. The key difference is that they have to add the off-site consequence analysis of a release.”
Risk Management Program Requirements
Poultry facilities that use threshold amounts of these chemicals must implement and submit an RMP plan by June 21, 1999. This plan must be made available to the public, and it must be submitted to the State Emergency Response Commission, the local emergency planning committee (if one exists for that county), and the local fire department. Walsh cautions, “Even though facilities have until 1999 to submit their RMP plans, they need to begin work on these as soon as possible, primarily because the analysis of the off-site consequences can take some time since maps are required, population data must be determined, and other factors must be evaluated.” Under RMP, facilities also are required to maintain records for five years, and facilities may be audited for compliance.
RMP contains three programs or tiers. Program 1 is for facilities (1) with no significant release of chemicals resulting in death, injury, response, or restoration for the previous five years and (2) where there is no public receptor (any commercial, residential, or institutional facility) inside the distance to the toxic or flammable endpoint. Because of this second requirement, it is likely that only very rural locations will be put into Program 1. Program 3 is for facilities subject to PSM. Program 2 is for facilities that do not fall under Programs 1 or 3. If a poultry facility is in PSM, it is automatically in Program 3 for RMP. Most poultry processors will be in Program 3 since they must have a PSM program for ammonia. Poultry facilities that are not in Program 3 and that must develop an RMP plan for propane probably will be in Program 2.
Walsh emphasizes that “if facilities have not completed their PSM program, they need to do that first because the RMP builds on the PSM program. In fact, the PSM program can be a part of the RMP.” PSM prevention program requirements (which are also applicable to RMP) include:
  • process safety information;
  • process hazard analysis, which includes
    what-if scenarios
  • checklist
  • hazard and operability analysis (HAZOP)
  • failure modes and effects analysis (FMEA)
  • fault tree analysis;
  • operating procedures;
  • employee participation;
  • training;
  • contractors;
  • pre-start-up safety review;
  • mechanical integrity;
  • permits for hot work;
  • management of change
  • incident investigation;
  • emergency preparedness;
  • compliance audits.
RMP plan requirements include:
  • executive summary;
  • registration and general plant information;
  • an off-site consequence analysis;
  • a five-year accident history;
  • a prevention program the same as for PSM (Programs 2 and 3 only);
  • an emergency response program;
  • certification.

Release scenarios
RMP requires facilities to evaluate two situations: (1) worst-case release scenarios; (2) alternate release scenarios. The worst-case release scenarios for various chemicals are defined by the regulations [40 CFR 68.25(c)(1)]. For example, ammonia release in the worst-case scenario is defined as the loss of the entire contents of the largest receiver (storage tank) of ammonia at the facility in 10 minutes.
In developing a worst-case release scenario for a chemical such as ammonia, poultry facilities need to evaluate the distance to what is called the toxic endpoint–the distance at which the concentration of ammonia falls below 200 ppm, which is considered a safe level. According to Walsh, in evaluating the toxic endpoint, poultry facilities will need to determine the populations and the environmental areas that could be affected within that distance.
The alternate release scenario is based on real life. Walsh comments, “The alternate release scenario is actually the most likely release amount for a chemical.” The RMP requires five years’ worth of accident history for determining what the most likely release amount is. Walsh leads a team of Georgia Tech researchers that is developing an alternate release scenario for ammonia in Georgia. The research team is currently downloading data from the EPA’s Emergency Response Notification System (ERNS), which contains the data for any release of ammonia in excess of 100 pounds that was reported to the EPA. The researchers are editing the data to eliminate ammonia releases from non-food-processing operations (for example, ammonia fertilizer storage), entries where the amount of the release could not be determined, and a release where the cause could not be identified. The researchers will use the edited data to determine the most likely amount of ammonia release and the cause of the release during a noncatastrophic failure. Georgia Tech researchers plan to have the State of Georgia Emergency Response Commission review the analysis so that an acceptable release amount can be used by all facilities. In addition, section 112(r)(1) has a “general duty” clause that requires a facility to “design and maintain a safe facility taking such steps as are necessary to prevent releases, and to minimize the consequences of accidental releases which do occur.”
Training requirements
OSHA 1910.120, which governs an on-site emergency response team, also applies to the RMP. Under these regulations, training to at least the awareness level is required of essentially all plant personnel who come in contact with any of the systems involved with the storage or use of certain chemicals. The on-site emergency response team must have technical-level qualifications requiring at least 24 hours of training. Any cleanup of a release requires additional training. In addition, an 8-hour annual refresher is required for the team. If a facility has an emergency situation, it will likely be visited by OSHA inspectors who will check to make sure that the training objectives were met.
The EPA web site (http://www.epa.gov/swercepp/pubs.html) has generic guidance documents available to assist facilities in implementing the requirements under RMP. These documents contain models for determining the distance to the endpoints, which are toxicity for ammonia and explosion for propane. The guidance documents also provide a model for determining distances to the toxic end point. Facilities may want to download the following documents from the web site:
  • Risk Management Plan Data Elements;
  • Risk Management Program (RMP) for Ammonia Refrigeration Facilities Generic Guidance;
  • Risk Management Plan for Propane.

 

Plan now to visit Georgia Tech at the 1998 International Poultry Exposition

The 1998 International Poultry Exposition (IPE) is rapidly approaching and Georgia Tech is pleased once again to be a part of this premier poultry event. Slated for January 21-23, 1998 at the Georgia World Congress Center in Atlanta, IPE will be celebrating its 50th anniversary and will again feature over 1000 exhibitors covering more than 14 acres of exhibit space.
Georgia Tech’s Agricultural Technology Research Program (ATRP) will be located in Booth 3319 in the Gold Hall. The exhibit will highlight ongoing ATRP technology research and prototype system development. Program engineers will be available to answer questions.
Make plans now to drop by and see us!

 

Credits
Dara O'Neil, Editor
Rae Adams, Contributing Editor and Photographer
Margie Brown, Contributing Editor
Nancy Davis, Contributing Editor
Caroline Fitzpatrick, Contributing Editor
Kevin Marshall, Contributing Editor