Liability Insurance Contributing Columnist


Breaking Through Workforce Language Barriers

M3 Insurance

June 15, 2018


The United States has one of the most diverse dairy industries in the world, producing both innovative and traditional products.

The US workforce is also becoming more diverse. Consider this: In 2015, immigrants made up close to 17 percent of the US civilian labor force, according to the Migration Policy Institute. This figure is up from only 5 percent in 1970.

Furthermore, many immigrant workers enter the workforce with Limited English Proficiency (LEP). (LEP is a term used in the United States to refer to anyone age 5 or older who reported speaking English less than “very well,” as classified by the US Census.)(1)
It’s important to note that although most of the Limited English
Proficiency population in 2015 was foreign born, 18 percent of those speaking English less than “very well” were born in the US.

With unemployment running at an all-time low, and competition for employees fierce, dairy processors must find solutions for maintaining a competent and well-trained workforce.

Let’s look at some of these challenges – for employees and employers – and some possible solutions.

Challenges for non-English speaking employees and their employers:
1. Communication barrier impacts training: This is the most obvious challenge. An employee who is unable to completely understand safety training (both OSHA training and food safety training) puts the workers (and the diary processor) at risk for accidents and food safety issues.

2. Compliance with OSHA regulations: OSHA’s policy states that employee training required by OSHA standards must be presented in a manner that employees can understand.
In practical terms, this means that an employer must instruct its employees using both a language and vocabulary that the employees can understand. For example, if an employee does not speak or comprehend English, instruction must be provided in a language the employee can understand. Similarly, if the employee’s vocabulary is limited, the training must account for that limitation. Furthermore, if employees are not literate, telling them to read training materials will not satisfy the employer’s training obligation.

3. Dependency on fellow employees for guidance: – Self-sufficiency is not only empowering, it also creates a more efficient employee. When an employee depends on a fellow employee – who is not a supervisor – for work instructions or to translate safety training – it creates inefficiencies. It can also put the non-English speaking employee at a disadvantage. Does the employee doing the translating fully understand the training concepts? Is there unintentional bias in how the information is being delivered? Is it really the fellow employee’s role and responsibility to make sure his or her coworker is trained?

Solutions to consider surrouning the above challenges include:
1. Providing avenues to increase the language proficiency of your employees. One way some employers are helping their employees grow as team members is to include English as a Second Language (ESL) class as an employee benefit offering.
Employers can offer the lessons onsite or by partnering with a local technical college. Some employers offer bonuses to those who participate or achieve certain credentials in the classes. And, as a best practice, consider focusing content on ESL as it pertains to your workplace environment and initiatives. The Department of Labor (Wage & Hour division) references employee training in regulations (Section 785.27) and should be consulted before developing an ESL training program.

2. Utilizing bilingual safety materials: OSHA provides tools for employers needing resources for non-English speaking employees at
The materials are becoming more available and comprehensive in scope. By including pictographs you can also reach employees who may be illiterate in their native language, or don’t thoroughly understand the languages. These can denote both correct and incorrect safety procedures and also denote hazards and reporting. Utilizing bilingual resources from the insurance broker or insurance carrier can also enhance your training program.

3. Hiring bilingual Supervisors/Directors of Safety: Many dairy processors are finding that the most direct solution is to hire supervisors and safety directors who are fully fluent in both English and a second language. This approach helps avoid problems associated with placing co-workers in a position of translating and interpreting training materials.

The first step toward safety in any processing plant is to recognize the need for addressing multi-language training before an accident, food safety issue or OSHA fine occurs. Luckily, dairy processors don’t need to undergo this effort alone. By relying on support and advice from trusted advisors – including your insurance broker – training and safety messages can be heard loud and clear – regardless of the language spoken.




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