Injuries in Food Manufacturing

TASA ID: 2482

Food manufacturing has one of the highest injury and illness rates compared to all industries. Repetitive motion, (Bureau of Labor Statistics, 2011) manual handling, slips and trips, and being hit by moving objects (Health and Safety Executive, 2011) are among the most common sources.

When assessing accident fault, investigators must consider many issues. An in-depth knowledge of food processing may be helpful to food manufacturing accident investigators in some areas, including (listed in no particular order):

1. Process/equipment

2. Maintenance

3. Sanitation and cleanup

4. Programs (e.g., HACCP, GMP's, SOP's)

5. Job description

6. Training

7. Facility layout

The remainder of this article will briefly explain the seven areas identified above and offer some insight on how specialized knowledge in each area may help investigators resolve injury cases.

The process/equipment area involves the handling and treatment of food and ingredients throughout the facility. The process and equipment related to the injury should be identified and defined. A diagram or description of the manufacturing process can be extremely helpful. Process machinery might include remote or mobile devices and change parts that are not normally noticed, but could play a significant role in fault assessment. Equipment modifications, non-standard applications, safety bypasses and workarounds must be discovered and analyzed.

Maintenance is the activity associated with keeping the mechanical equipment, structures and surfaces in a food processing facility in good repair to establish safe and efficient operating conditions. An ongoing and organized maintenance program is standard procedure for most food manufacturing facilities. Thorough and complete maintenance in a food processing facility may be difficult and require creative timing and coordination under stressful and busy operating conditions. Equipment should be kept up-to-date with attention to recalls and recommended upgrades. Accident investigations should include a detailed understanding of the maintenance environment of the plant, particularly around the area of the accident.

Sanitation and cleanup are ongoing activities that take place whenever food is being processed (Expert # 2944774768 & Young, 2000). Dedicated personnel may be periodically tasked with cleaning and sanitizing contaminated or soiled surfaces and those with which food comes in contact. Hot water and dangerous, corrosive chemicals can cause many hazards.  Recent advances in the industry have resulted in automated cleaning equipment that virtually removes the operator from harm's way and results in higher-efficiency cleaning. Accidents that occur during cleanup or as a result of cleanup must be analyzed with an understanding of manual and automated cleaning systems, physical/chemical properties of the food products, and how materials are moved throughout the facility.

Many programs (usually denoted with an acronym such as HACCP, GMP or SOP) are part of everyday activities in most food plants. These programs may be required by law (e.g., HACCP plan for USDA- inspected facilities), a particular client (sustainability for Wal-Mart), or an internal policy backed by management. HACCP, for example, stands for Hazard Analysis Critical Control Point; it has gained wide acceptance in the food industry, even when not required by law. A HACCP program requires a process flow diagram, which could give information that is critical to an injury case. GMP's are Good Manufacturing Processes and were developed to establish criteria in determining compliance with section 402(a) (4) of the Food Drug and Cosmetic Act. Some aspects of the GMP's have a direct impact on employee safety, like the requirement for complete drainage of liquids from floor areas. SOP's are Standard Operating Procedures; all companies employ SOP's, whether written or not. Some SOP's may be inherently dangerous or imply dangers in the process and environment.  For instance, an SOP to inspect a check valve in a culinary steam line implies that the valve may not have functioned properly in the past or that dangerous steam could escape.

An accident investigation should also review job descriptions which may reveal many potential risks and safety requirements associated with particular positions. Was the injured person acting within or outside of normal job responsibilities? Was the supervisor, coworker, maintenance technician, sanitarian, fork truck driver, or other related person acting within their expected area of responsibility?  Many job descriptions are poorly written or omit critical duties which must be performed as a condition of employment.

Most accidents are caused by errors, and better training reduces errors (United States Department of Labor, 1998). Training should be required for all jobs at all levels. Lack of training or ill-developed training in positions throughout a food processing facility can result in accidents. Some mandated (e.g., HACCP) or voluntary (e.g., SOP's) programs require training and may include validation procedures. The identification of training requirements and programs can help assess responsibility in the case of accidents. For example, under FSIS directive 4791.11 (FSIS, 1997), in USDA-inspected facilities, a lockout/tagout plan is required. Qualified personnel must be trained to lock and tag out equipment that is not in use or is undergoing maintenance.

Safety features are an integral part of food facility layout and design (Expert #2944774768, 2006). Facilities should be designed not only to reduce the dangers of fires, earthquakes and other natural disasters, but  also to facilitate processes, movement of materials, energy conservation, safety and communications, and more. Floor, wall and ceiling surfaces, drain locations, lighting, utility runs, and many other building features can be contributing factors in injury cases. Employees and supervisors may experience job frustration and even fear because of the difficulties associated with working in poorly designed facilities. These feelings may be expressed toward coworkers, or blamed on equipment or ingredient faults, but in fact, can be attributed directly to facility design. Experience with and an understanding of good facility design practices and outcomes could be helpful in solving many injury cases.

Injury investigators in food manufacturing often face a difficult task. Complex issues may require an in-depth understanding of food processing and engineering. This article introduced seven of the more common issues. An expert with processing and engineering experience can provide a great deal of insight into problem solving, identifying important issues, evaluating alternative explanations, and outlining approaches that help those involved gain knowledge that leads to resolution.

References

Expert #2944774768 and J. Young. 2002 Process and Facility Sanitation. Available at:  http://www.fapc.okstate.edu/files/factsheets/fapc121.pdf. Accessed on 11MAY11.

Expert #2944774768  2006. Food Processing Facility Design. In Handbook of Farm, Dairy and Food Machinery. Myer Kutz, editor. William Andrew Publishing, New York. pp. 579-608.

Bureau of Labor Statistics, 2011. Food Manufacturing, available at: http://www.bls.gov/oco/cg/cgs011.htm. Accessed on 11MAY11.

FSIS, 1997. Lockout/tagout safety procedures. Available at:  http://www.fsis.usda.gov/FOIA/dir/4791-11.pdf. Accessed on:  11MAY11.

Health and Safety Executive, 2011. Main causes of injury in food and drink manufacture, available at:  http://www.hse.gov.uk/food/causes.htm. Accessed on 11MAY11.

United States Department of Labor. 1998. Occupational Safety and Health Administration studies of accident injury data and training effectiveness. Available at:  http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=1078&p_table=PREAMBLES. Accessed on 11MAY11.

This article discusses issues of general interest and does not give any specific legal or business advice pertaining to any specific circumstances.  Before acting upon any of its information, you should obtain appropriate advice from a lawyer or other qualified professional.

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