The sanitation shift can be an assault on the senses, full of steamy sprays and overwhelming fog, antiseptic or unpleasant aromas, squelching sounds, and slippery surfaces. If you've ever stepped onto a food production floor at midnight and witnessed the bustle of activity, you know that something important is happening. Employees are racing against sunrise to get equipment dismantled, scrubbed of soil, rinsed, sanitized, and reassembled before operations can begin anew the next day. Add in some repair activity or unforeseen maintenance task, a smorgasbord of potent chemical solutions, sometimes minimal oversight by management, and regular staff turnover, and the potential for accidents to happen on third shift multiplies.  

Nationwide, sanitation and maintenance workers represent a small percentage of the food processing workforce, depending on the type of operation (e.g., fresh versus further processing), but represent significantly higher rates of occupational injury than other industries. Based on roughly 1.6 million people employed in food manufacturing,¹ the sanitation and maintenance population ranges from 45,000 to 90,000 workers. The incidence rate of nonfatal occupational injuries and illnesses in food manufacturing hovers at around 5.1 per 100 full-time workers (compared to manufacturing as a whole, at 4.0). However, documenting the incidence rate for sanitation work in food processing is complex because workplace injuries are not reported by job classification.  

This critical operation keeps food manufacturing companies functional and profitable. Yet, sanitation and third-shift maintenance can be among the most hazardous jobs in food and beverage production plants. In spite of the risks, these positions are often the least compensated and supervised. Facility audits or inspections at 2 a.m. are typically not commonplace. Sanitors face harsh environmental conditions and numerous hazards including chemical exposure, electrical shocks and burns, slips/trips/falls, being struck by or caught in moving equipment, and cuts/lacerations from blades and saws. These hazards have resulted in severe injuries such as amputations, crush injuries, blunt force trauma, and even death. Beyond the physical hazards, third-shift employees often face debilitating fatigue as many hold an additional day job, and many, especially in the meat and poultry industry, face the ongoing stress of being foreign-born non-citizens.²

The constant calls for increased production to meet the growing demand for certain food products, especially protein, have also decreased the number of hours available for sanitation activities as production lines can sometimes operate later into the night. As U.S. Department of Agriculture (USDA) inspectors also need time to conduct a pre-operational inspection, this ultimately translates to a faster working pace for crews already operating in a treacherous environment. Alterations made on production equipment to improve efficiency on first and second shifts—automated blades, belts, screw augers, and conveyors, for example—result in extra surfaces that will be soiled and, therefore, must be sanitized. Process innovations or retrofits in the machinery used—abrasive rollers, drum blenders, and augers, mixers, pelletizers, grinders, extruders—improve operational versatility. Still, all are energized, all include moving parts, and all hold risk for employees who work with and around them.

At some point, operational efficiencies used to reduce sanitation time will result in a higher risk to both food and worker safety. Sanitary or hygienic design may not have been in mind when the original equipment was purchased and installed. Unfortunately, rarely is worker safety part of the conversation when it comes to the mechanical engineering of the new machinery design. Worker safety features are almost exclusively designed for operational workers, not sanitation employees. Excluding these voices during the decision-making for process and production improvements can result in unforeseen (and potentially deadly) consequences for consumers and workers alike.  

That new drum breader or sorting conveyor may increase the item per minute rate, but it might be difficult to access for thorough cleaning unless a sanitation worker removes a protective guard or physically enters the equipment. In some cases, employees report that machinery must remain energized (e.g., powered on) to access all surfaces that must be cleaned, creating highly hazardous work conditions. Also, simply cutting the power does not always remove the danger of unexpected moving parts. Residual energy can be present in unplugged machines, and some equipment can be energized using non-electrical means, such as compressed air. Sadly, most sanitors have stories of equipment unexpectedly moving, even after being properly locked out.

Alarm Bells

The majority of the USDA, USDA Food Safety and Inspection Service (FSIS), and U.S. Food and Drug Administration (FDA) regulations around food safety and sanitation exist to protect the health and well-being of consumers, with the goal of preventing product recalls, foodborne illness outbreaks, and other consequences. These federal cleanliness requirements include a stringent approach to facility sanitation; prevention of harmful pathogen growth and contamination is of highest priority because the potential fallout from a misstep could be catastrophic for both consumers and the company reputation. Data is tracked through the FDA and USDA recall databases, as well as through the Reportable Food Registry, which holds producers accountable.  

While the hazards of food production activities and deficient sanitation practices are well known—dating back to the publication of Upton Sinclair's The Jungle in 1906 and the resulting passage of the Meat Inspection Act and the Pure Food and Drug Act—it was not until the creation of the Occupational Safety and Health Act of 1970 that employee safety was prioritized at the federal level. For sanitation crews, the applicable regulations under the Occupational Safety and Health Administration (OSHA) can be challenging because, regularly, this work has been contracted out, muddying the waters around responsibility for appropriate safety measures between plant and contractor. The result is that the sanitation employees themselves—often foreign-born non-citizens with minimal understanding of their rights as an American worker and with English as their second or third language—find themselves not provided with the appropriate training or supervision.  

In recent years, employee safety in food and beverage manufacturing facilities has come under increasing scrutiny by regulators, employee advocacy groups, and the consuming public alike. COVID-19 outbreaks in meat processing facilities were regular news headlines during 2020 and 2021. Well before COVID-19 struck, however, OSHA (particularly in Region 4) had noted that some of the most horrific accidents occurring in poultry processing and meatpacking plants involved the maintenance and sanitation workers. For example, in 2004, after the poultry industry reported 14 fatal accidents in the years between 1999 and 2004 involving these third-shift activities, heightened enforcement for this industry sector was initiated in OSHA Region 4.  

What happens when OSHA identifies a concerning trend of injuries or fatalities in a specific industry? Often, in lieu of considering pursuit of a new regulation (an onerous, lengthy, and often legally fraught process), an Emphasis Program will be created instead. An Emphasis Program is a type of OSHA Enforcement Program that includes both heightened outreach to affected businesses in the form of training or informational meetings and mailings, as well as increased inspection activity by OSHA compliance officers. These Emphasis Programs, which can be national in scope or targeted to a local region, often concentrate on specific components of a regulation, hazards of a specific work activity, or expected control strategies. OSHA uses the North American Industrial Classification System (NAICS) code to help narrow the scope of affected industries. For example, OSHA Region 4 (which includes Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, and Tennessee) has a Regional Emphasis Program addressing Sanitation and Clean-up Operations in the NAICS Groups 311xxx and 3121xx—food and beverage manufacturing.³ Included in this Emphasis Program are observation of the work and documentation of employee training.

Strategies for Safer Sanitation

In the U.S., immigrants working in food processing or food manufacturing comprise approximately 29 percent of the industry's total workforce (although this may vary by state), and these workers often have low levels of English language proficiency.⁴ Approximately 41 percent of immigrants score at or below the lowest level of English proficiency—"below basic" or "functional illiteracy,"⁵ but OSHA expects employee training to be conducted in "a language and vocabulary and in a manner that an employee can understand." Often, however, the content of the material required to be covered can be complex, full of confusing chemical product names or equipment-specific procedures—words or concepts that do not translate easily. Combine these challenges with the lack of time to properly complete training,⁶ and high employee turnover and inadequate training programs can result.

One way OSHA supports businesses in achieving the mandatory requirements of training employees on the hazards of their job tasks (and in preventing harmful outcomes) is through an annual competitive grant for nonprofit organizations called the Susan Harwood Grant Program. Established in 1997 to honor the former Director of the Office of Risk Assessment in OSHA's Health Standards Directorate, the grant program's applications are solicited and awarded to organizations that will develop and provide training and education programs on certain high-hazard topics. Typically, the training materials developed by the grantees are tailored to meet specific target audiences, including hard-to-reach workers such as temporary, non-literate, low-literacy, or limited English proficiency, and the final materials are posted on OSHA's website for free download. Two training areas where resources have been specifically developed to improve access for food and beverage sanitation crews are detailed below.

Sanitation Chemical Safety

Chemical hazard communication is a critical component of OSHA-required employee safety and health training related to disinfection, sanitation, and sterilization in the food processing industry. The detergents, sanitizers, and other cleaning products used in this industry must be aggressive to meet USDA, FDA, and Hazard Analysis and Critical Control Point (HACCP) requirements. The products' chemical complexity and frequency of use can create significant dermal and inhalation exposures for employees.

Georgia Institute of Technology was one of the 2018 recipients of a Susan Harwood grant to develop a Hazard Communication Training on Disinfection, Sanitation, and Sterilization Products used in Food Processing Facilities. Training presentations were developed in five languages commonly used in food processing facilities: Spanish, Arabic, Burmese, Haitian-Creole, and Swahili. The training courses are freely available on Georgia Tech's Safety, Health, and Environmental Services group's YouTube Channel.⁷

The training modules cover a basic overview of why understanding the sanitor's role in company success is so important, a review of the OSHA hazard communication standard, discussion of the commonly used chemicals in food processing, physical and health hazards associated with exposure to these chemicals, container labeling information, and how to report a concern in the workplace. Western North Carolina Worker's Center also received a 2017 OSHA grant to develop a similar training system, specifically for the poultry industry. Their developed resources are available, also for free, on the OSHA website.⁸ 

Another great source of applicable training information is chemical suppliers. These vendors are experts in the use, challenges, and safety aspects of the cleaning chemicals that are being used. Often, monthly refresher training is offered as a part of their contracts. A company's chemical representative is also a good resource for sanitation troubleshooting, either for food safety issues or employee safety concerns.

Equipment Safety

Every fiscal year, OSHA releases its "Top 10 Most Frequently Cited OSHA Standards." For the last five years, control of hazardous energy when workers are servicing or maintaining machines and equipment has landed on the fourth, fifth, or sixth spot. The inspection profile from FY 2021 recorded the control of hazardous energy, known as lockout/tagout (LOTO), as accounting for more than one-third of the most frequently cited standards for the food industry. Hazardous energy can be electrical, mechanical, hydraulic, pneumatic, or others, and this energy can be both stored and unexpectedly released (such as when a jammed conveyor system suddenly clears) or occur when equipment or machinery starts without warning (e.g., equipment on a timer begins operating despite someone still working on it).

As highlighted previously, pinning down exact statistics around food industry sanitation is challenging because the sanitation industry uses multiple job codes, making it difficult to search the data. Also, if a plant is using a sanitation contractor service, then the facility is not obligated by OSHA to report contractor injuries. Regardless, we know from fatality investigations conducted by OSHA and the National Institute of Occupational Safety and Health (NIOSH) that a key contributing factor to amputations and deaths associated with third-shift sanitation operations is the absence of an effective LOTO program.  

It may be helpful to think of LOTO as a Critical Control Point (CCP) in the HACCP plan—i.e., a point or procedure where the loss of control could result in an unacceptable risk. Food sanitation managers view CCPs as the place where food-related hazards can be prevented, eliminated, or reduced to safe levels; a safety professional views these job functions and associated hazards through the Hierarchy of Controls.⁹ Every safety professional knows that a robust LOTO program includes several elements:  

• Comprehensive hazardous energy control procedures that are established and followed
• A review ensuring that all components of new or modified equipment, including safety devices, are properly installed and functioning before use begins
• Completion of hazard evaluations before process and system modifications are implemented
• Established safety programs that include procedures requiring workers to communicate potential hazards to safety managers.

Failing to complete these steps at any point in the program can result in unacceptable risk. An instinctive response to a complex situation is to slow down and take more time, but the challenge here is often that these high-hazard worker exposures are at odds with the message that "increased pace is increased profit." Proper pre-planning, noting the obstacles and challenges, and committing to ongoing feedback and improvement within and between crews and departments can help alleviate these risks. Both the OSHA and NIOSH websites offer specific resources to ensure comprehensive development of LOTO programs, and numerous Susan Harwood Grants have addressed this high-priority issue.  

Rise and Shine

Food safety managers and quality assurance leaders can significantly contribute to the physical safety of sanitation crews by more fully exploring the inherent hazards and risks of appropriately cleaning the processing equipment. During a periodic equipment cleaning where an equipment teardown, reassembly, and restart is required, managers may consider evaluating the task through both the food safety and employee safety perspective. Does the necessary disruption of a harborage site for an organism require a sanitation employee to compromise their safety? How does that worker access a particular area of the equipment to perform the necessary cleaning step—do they have to reach into, around, under, or through machinery that could catch or snag them? Does the equipment require physical scrubbing by hand to remove a soil, or can an extendable brush or tool be used? These jobs are interdependent, and observing how they interact is essential to developing and implementing a truly effective training program.

Communicating about the desired outcomes, expectations, and requirements of the tasks is where engagement by the facility safety department and sanitation crew (or contractor) is critical. This ensures that everyone is on the same page regarding the challenges and potential solutions, which is especially important if the processing equipment/machinery is older or not constructed with the most current hygienic design principles. As noted previously, in response to the high injury rates, there is also a trend of increasing employee safety features in new equipment (e.g., shielding pinch-pints and added guards), which, in turn, could restrict access and increase the burden for sanitation crews. In these cases, it is likely that more aggressive cleaning and sanitation procedures are needed to achieve the required pathogen reduction; this also means that the risk to the employee performing that cleaning activity may be higher. This juxtaposition of varying needs is highlighted in the recent conversation around ISO/TC 326, where development of international standards encompassing individual machines through full processing systems addresses both food hygiene and employee safety. The American Society of Agricultural and Biological Engineers (ASABE), which is administering the U.S. technical advisory group for ISO/TC 326, has called for input on this process.

As Joe Stout, R.S., noted in his 2016 Food Safety Magazine article, "Hygienic Design: How Our Thinking Has Evolved," "It is not acceptable to wait a generation for change."¹⁰ The same can be said for both contamination control and preventing devastating employee injuries. Stout highlighted how an "…easily cleaned food plant establishes a firm foundation for a sanitary environment," and that while, in theory, everyone supports hygienic design, convincing leadership to commit the time and money to replace or retrofit equipment and processes is challenging. Safety departments arguing for improved controls or procedures for sanitation crews often run into similar barriers, facing the questions of "How much will it cost?" and "How will it impact operations?" Working together, both departments can support each other to achieve their intended goals. In the end, it is vital to ensure that sanitation employees are receiving effective training and that management is giving proper attention to this high-risk sector.

References

1. U.S. Bureau of Labor Statistics. "Databases, Tables & Calculators by Subject: Employment, Hours, and Earnings from the Current Employment Statistics survey (National)." 2022. https://data.bls.gov/timeseries/CES3231100001?amp;data_tool=XGtable&output_view=data&include_graphs=true.
2. Cain, Áine. "The meat industry is hiding a dark secret, as workers at 'America's worst job' wade through seas of blood, guts, and grease." Business Insider. January 4, 2018. https://www.businessinsider.com/meat-industry-sanitation-workers-2018-1.
3. OSHA. "Regional Emphasis Program (REP) addressing Sanitation and Clean-Up Operations in the NAICS Groups 311xxx & 3121xx." October 1, 2019. https://www.osha.gov/enforcement/directives/cpl-20-06-cpl-04.
4. Desilver, Drew. "Immigrants don’t make up a majority of workers in any US industry." FactTank: News in the Numbers. Pew Research Center. March 16, 2017.
5. Richwine, Jason. "Immigrant Literacy: Self-Assessment vs. Reality." Center for Immigration Studies, June 21, 2017. https://cis.org/Immigrant-Literacy-Self-Assessment-vs-Reality.
6. "Food Safety Update: Employee Training." Food Manufacturing (December 2, 2015). https://www.foodmanufacturing.com/facility/article/13185030/food-safety-update-employee-training.
7. Georgia Tech. "Safety, Health, and Environmental Services EI2: Playlists." YouTube. https://www.youtube.com/channel/UCOcEr-guU-hHajHKX1PtZuA/playlists.
8. U.S. Department of Labor, OSHA. "Western North Carolina Workers' Center—SH-31206-SH7." 2017. https://www.osha.gov/harwoodgrants/grantmaterials/fy2017/sh-31206-sh7.
9. Warren, Hilarie, Jenny Houlroyd, and Wendy White. "Food Safety and Employee Safety: Two Sides of the Same Coin." Food Safety Magazine (February/March 2022). https://digitaledition.food-safety.com/february-march-2022/feature-spotlight/?oly_enc_id=6399D5390667E5K.
10. Stout, Joe. "Hygienic Design: How Our Thinking Has Evolved." Food Safety Magazine (December 2017/January 2017). https://www.food-safety.com/articles/5115-hygienic-design-how-our-thinking-has-evolved.

Hilarie Warren, M.P.H., C.I.H., manages the OSHA Training Institute (OTI) Education Center at Georgia Tech, one of the first OTI Education Centers in the national network of occupational safety and health training organizations authorized by OSHA. She enjoys helping companies translate regulatory requirements and move into implementation by providing opportunities for training attendees to share best practices and stories.

Jenny Houlroyd, M.S.P.H., C.I.H., has worked as an industrial hygienist with the OSHA Consultation Program for 16 years, providing onsite OSHA compliance assistance for businesses throughout the state of Georgia. She serves as the Manager of the Occupational Health Group for that program. This free program is designed for small- and medium-sized companies to assist employers with achieving regulatory compliance and ensuring that they provide safe and healthful working environments for employees.

Wendy White, M.Sc., is the Food and Beverage Industry Manager for the Georgia Manufacturing Extension Partnership (GaMEP) at Georgia Tech, a state, and federally funded program that helps manufacturing companies increase top-line growth and reduce bottom-line costs through onsite projects, training, and connections to other resources. Ms. White leads GaMEP's food industry services, which include regulatory compliance, HACCP food safety plans, and third-party audit certification preparation. She holds a B.S. degree in Biology and an M.Sc. degree in Food Microbiology from the University of Georgia and is an FSPCA PCQI Human Foods Lead Instructor, an International HACCP Alliance Lead Instructor, and an ASQ Certified Quality Auditor. She is also a member of the Editorial Advisory Board of Food Safety Magazine.