Over the last seven years, in response to high rates of worker deaths and injuries, OSHA launched two localized efforts to improve working conditions on dairy farms. Today, a new study finds the efforts made a positive difference, with farmers describing the intervention as a catalyst for reducing workplace dangers.
The study, just published in the August issue of the American Journal of Industrial Medicine, examined the impact of two OSHA Local Emphasis Programs (LEP) that addressed dairy farm conditions — one launched in 2011 in Wisconsin and another in 2014 in New York. An LEP is an enforcement strategy designed and implemented by a regional OSHA office and intended to address workplace hazards specific to that office’s jurisdiction through employer outreach and education. The New York and Wisconsin dairy farm LEPs rolled out in response to disproportionately high worker fatalities, targeted farms with 11 or more workers, and included random, unannounced inspections. (The New York LEP launched after dairy workers, with the help of local worker centers, spoke up about unsafe and abusive conditions. We wrote about the worker-led push for the New York LEP back in 2014 — read it here.)
The study noted that New York and Wisconsin dairy farms represent a big proportion of occupational deaths among dairy workers, with the number of combined deaths making up 39 percent of such fatalities between 2000 and 2014. Nationally, 659 dairy workers lost their lives in fatal workplace incidents in that time period. Farming is already one of the most dangerous jobs in America, and farm conditions are often ripe for worker exploitation due to big gaps in federal labor laws that specifically exempt agriculture.
“In other industries, studies offer evidence that improvements in worker health and safety did not markedly impact production expense and business sustainability,” researchers wrote. “More importantly, research suggests that standards and their potential enforcement have a positive impact on worker health and safety.”
To gauge the impact of the New York and Wisconsin LEPs, researchers examined reports and data from a variety of sources, including OSHA, state labor agencies and farmworker health organizations, as well as responses from telephone surveys of dairy farmers in each state. In New York, the study reported, the LEP brought together a number of farming organizations, from the New York Farm Bureau to the New York Center for Agricultural Medicine (NYCAMH), to work on getting ready for the coming OSHA inspections. The new work group connected farmers to worker health and safety professionals and helped disseminate safety guidance and protocols. Study co-authors Amy Liebman, Eileen Franko, Iris Reyes, Matthew Keifer and Julie Sorensen write:
The most significant benefit of the work group was that it brought together agencies and organizations that were trusted by New York dairy farm owners. The work group’s objective was to collaboratively identify workplace hazards and offer suggestions for how they could be corrected to ensure OSHA compliance. A variety of on-farm services were offered to farms, mostly through NYCAMH’s staff of safety trainers. … Organizations were also able to collectively discuss options for correcting hazards, where no previously agreed upon engineering or administrative controls had been established.
Telephone surveys with New York dairy farmers took place after the initial round of LEP inspections and queried both inspected and uninspected farms. Farmers reported facility and safety upgrades ranging from a median of less than $4000 for uninspected farms to over $10,000 for inspected farms. More than half said the LEP inspection process was “confusing” and that OSHA didn’t provide needed clarifications on issues like bunker silos and manure storage. However, more than half reported changes in workers’ behaviors following safety training, and 100 percent said they had benefited from the LEP experience.
Compared to New York’s response to the LEP, Wisconsin’s response was “relatively muted,” researchers wrote. In Wisconsin, the LEP motivated farmers to partner with the National Farm Medicine Center to conduct safety audits and implement a Spanish-language health and safety program for workers that ended up training more than 800 workers on 67 farms. According to the study, focus groups with workers and results from the health and safety program “indicated workers desired safety and health training and had benefited from it.”
Telephone surveys of Wisconsin diary farmers found that awareness of the LEP tended to influence whether a farm made changes. In fact, among those that reported changes, 92 percent said their actions were motivated, in part, by the LEP. The most common safety improvements were in better signage, personal protective equipment, tractor safety and manure management.
Overall, farmers in both states described the LEPs as a “catalyst to reduce hazards on their farms,” researchers wrote.
“While the LEPs in Wisconsin and New York mobilized different preparation strategies, the outcome of raising awareness of hazards in the industry and acceptable methods to correct them was accomplished in both states,” the study concluded. “The results of the assembled data suggest that an LEP helps to identify high-hazard industries and educate employers on how to correct these hazards, even before the OSHA inspection activity begins.”
To download a copy of the new worker safety study, visit the American Journal of Industrial Medicine.
Thank you for highlighting this work. You can access the paper here: https://onlinelibrary.wiley.com/doi/abs/10.1002/ajim.22868 or feel free to email mail aliebman@migrantclinician.org
Please note that our description of “muted” in terms of the dairy owners response was about how they felt about the initiation of the LEP. In general they simply wanted to know how to comply.