As OSHA Continues Focus on Food Processors, Dairy Can Demonstrate Its People-First Culture

Just over a year ago, the Occupational Safety and Health Administration (OSHA) announced a new focus, a Local Emphasis Program (LEP) for food processors in Wisconsin, following a troubling uptick in serious injuries in manufacturing plants.

Now, OSHA officials are calling their efforts “fruitful.” Between July 2022 and July 2023, OSHA inspections of 48 Wisconsin food processing facilities, including dairy processors of varying sizes, resulted in 190 citations and penalties of $2 million.

Based on early outcomes in Wisconsin, OSHA expanded the LEP in January to include food processors across Region 5, and inspections – and citations – are now happening in Illinois and Ohio.  Could a national expansion be next?

It’s a fair question – and a fair concern for any food processor.

Inspections lead to fines and, beyond the immediate hit to a bottom line, they can tarnish the reputation of a business, or even an industry, limiting the potential for growth.  Harder still, though, are actual workplace injuries.  While the human toll can reach far beyond numbers, it is estimated that U.S. employers pay almost $1 billion per week for direct workers' compensation costs alone.

OSHA’s online estimator tool, found at www.osha.gov/safetypays, reveals the average direct and indirect costs for the most common employee injuries. Direct costs include workers’ compensation payments, medical expenses, and legal services, while indirect costs may stem from accident investigations, lost productivity, equipment repairs, and the training of replacement employees.  It all adds up.  A simple laceration, for example, will cost an employer an average of $48,000. A fracture will mean expenses of $115,000 and an amputation tops more than $200,000.

Moreover, “OSHA’s goal is not penalties, but hazard elimination,” says OSHA Assistant Area Director David Schott, who hails from the Appleton, Wisconsin office where the LEP originated. “We just want people to be safe at work.”

On that point, dairy processors fully agree – and focusing on that area of shared value, they can view this program as an opportunity to demonstrate their people-first culture, proactively assessing safety protocols and equipment, and taking action to adjust as needed.

We have direction on where food processors can improve. Schott notes that in OSHA’s first year of program enforcement, the most frequently cited violations related to machine guarding, lockout/tagout, fall prevention, confined spaces, and hazard communication. Thanks to a Wisconsin Cheese Makers Association (WCMA) member that experienced an early LEP inspection, we know that OSHA is also keenly focused on recordkeeping, safety training that covers proper equipment handling, chemical usage, and emergency protocols, and personal protective equipment, including hard hats where necessary, safety footwear, safety glasses, and hearing protection.

OSHA regulations in each of these areas are well-defined, and dairy processing plant managers should take time with their safety leads to regularly review each of these areas – on paper and in practice. 

But outside viewpoints can be valuable, and resources are available. Consider scheduling a no-cost, confidential meeting via OSHA’s on-site consultation program, which employs state agency or university staff, working separately from OSHA enforcement, to identify workplace hazards, provide advice for compliance with OSHA standards, and assist in establishing and improving safety and health programs.  On-site consultants will not issue citations or propose penalties, or report possible violations of regulations to OSHA enforcement personnel. Complete information is available at https://www.osha.gov/consultation.

Dairy processors may also consider their supplier partners’ expertise: a good vendor can help to solve common safety challenges.  From specialized signage to cutting-edge equipment and improved PPE, tailored solutions are available for every workplace.

Finally, consider engaging with trade associations offering platforms for industry peers to connect for practical conversations about employee safety practices.  Members of WCMA’s Health & Safety Group, meeting quarterly, have created a “safe” space for learning from one another and from experts in much the same way as our industry has long shared information on food safety, to the benefit of all.

Taking steps now to assess and enhance safety practices may save dairy manufacturers from tens of thousands of dollars in fines, as OSHA continues – or further expands – its focus on food processing.  Beyond compliance, a robust safety culture also will prevent costly accidents and injuries, and protect the well-being and trust of any dairy processor’s most valuable asset: its workforce.

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