Liability Insurance Contributing Columnist


Prioritizing Worker Safety Will Never Become Antiquated

Jen Pino-Gallagher
Director of Food & Agribusiness Practice
M3 Insurance

September 15, 2023


A lot has changed in the world of cheesemaking since the early stages of the dairy industry in the 1800s when copper kettles heated over an open fire were the norm. While these early cheese plants likely produced excellent cheese, the work environment was certainly not the safest.

Enter the modern cheesemaking era: zero open fires — dozens of safety regulations.

Focus on safety at every stage – from production to packaging
The regulations in place are intended to keep workers in the United States safe as they turn out over 14 billion pounds of cheese annually. But, as shown in a report in the Journal of Safety Research food processing in general is still considered a high-risk industry.

The report showed that workers were at risk of injuries at multiple stages of the food processing supply chain, including in the packaging and distribution space. The researchers theorized that product movement, not only production, can be a source of occupational injuries. The report went on to explain that food processors “often use palletizers to aggregate individually packaged food products into a unit load before they can be transported using a pallet jack, forklift, or other powered industrial truck (PIT).”

No copper kettles, but plenty of opportunities for workers to encounter potentially dangerous environments as they process, package, and move food through the supply chain.

Key risks for dairy processors
According to Michael Pate, associate risk manager at M3 Insurance, there are key areas dairy processors can focus on to enhance worker safety in the dairy processing space and in food movement in general.

1. Equipment Safety: OSHA is paying special attention to equipment safety via the Local Emphasis Program established in 2022 focusing on the food industry. Inspectors, during unannounced visits, are paying special attention to machine guarding hazards and hazardous energy control programs associated with servicing, maintenance, setup, and sanitation of equipment, including thermal injuries from contact with hot or cold equipment.

Implementing regular equipment maintenance schedules, safety checks, and providing comprehensive training on proper equipment operation can significantly reduce risks, as well as potential fines from OSHA. Dairy processors should pay special attention to:
•Ensuring all food processing equipment is adequately guarded in accordance with 1910 Subpart O – Machinery and Machine Guarding.
•Evaluating your hazardous energy control program to ensure all components are in compliance with 1910.147 – The control of hazardous energy (lockout/tagout).

2. Ergonomic Hazards: Tasks such as lifting heavy items, repetitive movements, or working in uncomfortable positions are common in food processing and can lead to musculoskeletal disorders. Ergonomically designed workstations, mechanical lifting aids, regular job rotation which should be done at four-hour intervals for strenuous or repetitive tasks, and worker training on proper body mechanics can help mitigate these ergonomic hazards.

Does your plant run multiple shifts? Establishing training protocols that reach every shift are also critical for plants and warehousing facilities that run round the clock. As a best practice, consider developing a stretching and warm up routine for all shifts. This is a great way to prepare our bodies for athletic endeavors, but the correlation to physical tasks at work is often a missed control opportunity.

3. Slips and Falls: Dairy plants are known to be wet environments, which can lead to slippery floors. While non-slip footwear is one of the first remedies, don’t overlook the need for adequate lighting.

Additionally, studies have shown time and again that changing levels, whether a stair step, or a raised crack in the floor, is a major risk factor for slips and falls. Try to mitigate level changes wherever possible and ensure they are clearly marked and well lit.

4. Noise Exposure: Constant exposure to noise from machinery can lead to noise-induced hearing loss. Why does this happen? The human ear contains about 16,000 hair cells within the cochlea. These hair cells allow your brain to detect sounds. If these hair cells become damaged or destroyed, you’ll notice hearing loss. Up to 30 to 50 percent of these hair cells can be damaged or destroyed before changes in hearing can even be measured.

After leaving a concert or standing next to loud equipment you may notice you aren’t hearing as well as before. This is an indication that your cochlea hair cells have been damaged and become bent. Oftentimes, these hair cells will recover and straighten, but over time and with continued exposure you will continually lose these hair cells. Once they are dead, they cannot be recovered.

Regular noise assessments (checking that noise has not reached 85 dBA (OSHA action level)) over an eight-hour time weighted average should be completed. If 85 dBA is reached or exceeded, a hearing conservation program must be implemented. The use of noise reduction technology such as vibration dampening, sound absorbing materials, and use of high efficiency engines can help reduce noise exposure.

If hearing protection is required, select hearing protection with a NRR (Noise Reduction Rating) that adequately protects workers from the exposure. Utilizing layout design of the work area can also minimize noise exposure and can help to control this risk.

5. Chemical Exposure: Whether your equipment is cleaned in place (CIP), cleaned out of place (COP), or manually cleaned, the one commonality is potential worker exposure to sanitizing chemicals. It is critical that workers know the hazards associated with the chemicals they are using. According to OSHA, proper training must include (but is not limited to):
•Warning workers not to mix cleaning products that contain bleach and ammonia
•Making sure that workers know which cleaning chemicals must be diluted and how to correctly dilute the cleaners they are using
•Ensuring that all containers of cleaning products and chemicals are labeled to identify their contents and hazards
•Operating ventilation systems as needed during cleaning tasks to allow sufficient air flow and prevent buildup of hazardous vapors

6. Psychosocial Hazards: The demanding nature of the dairy industry can lead to stress, fatigue, and other mental health issues. It’s becoming more common for safety professionals to partner with their human resources teams to create a supportive workplace culture, provide access to mental health resources, and promote a healthy work-life balance to help mitigate these hazards.

While open copper kettles slung over wood burning fires are now ancient history in today’s dairy plants, the need for worker safety, training and a culture of safety will never become antiquated. Prioritizing worker safety is not just a regulatory requirement; it’s a strategic investment that can result in increased productivity, reduced downtime, and overall business success


Jen Pino-Gallagher is director of the food and agribusiness practice at M3 Insurance. M3 Insurance offers insight, advice and strategies to help clients manage risk, purchase insurance and provide employee benefits. The views expressed above do not necessarily reflect those of Cheese Reporter. You can contact the columnist by calling (800) 272-2443, or by visiting


Jen Pino-Gallagher

Jen Pino-Gallagher is a Director of Food & Agribusiness Practice at M3 Insurance. M3 Insurance offers insight, advice and strategies to help clients manage risk, purchase insurance and provide employee benefits.
For more information, call (800) 272-2443 , visit

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