In comments on proposed rules, authors of key federally-commissioned studies say
Trump Administration’s safety assurances misrepresent their work
Proposed USDA rules that would allow industrial animal ag corporations to speed up chicken, turkey, and hog slaughter and processing are based on a misreading of landmark worker safety studies, the co-lead principal investigators of those studies say in comments submitted late yesterday.
Dr. Carisa Harris-Adamson and Dr. Robert Harrison are concerned that USDA’s proposal to increase line speeds is going to make the rate of worker injuries worse and “fundamentally misunderstands and mischaracterizes the scope and results of” their studies.
Their comments on the proposed rules for poultry y swine, prepared by FarmSTAND, urge an approach to federal regulation of meat and poultry processing lines that factors in the pace of manual work along those lines, not just the rate at which animals move down them. The proposed rules would raise the allowable “evisceration rate” line speed from 140 to 175 birds per minute for chickens and from 55 to 60 birds per minute for turkeys, and eliminate the maximum speed for swine.
El Processing Line Speed Evaluation (PULSE) Studies on poultry y swine led by Harris-Adamson and Harrison were commissioned in 2022 by the USDA’s Food Safety and Inspection Service. They “assess the relationship between evisceration line speed in young chicken and swine slaughter establishments and the scope, magnitude, and factors that influence worker safety and health risks for establishment employees impacted by the speed of the slaughter line.”
The researchers affirmed that injuries are very common on the line: 81% of chicken processing workers and 46% of swine processing workers were at high risk of musculoskeletal disorders across facilities with different line speeds and work conditions. In yesterday’s comments, Harris-Adamson and Harrison note that their study of swine workers showed that if establishments increase evisceration line speeds without adjusting staffing levels, workers’ MSD risk increases.
The PULSE studies indicated that decreasing the “piece rate” (the number of items handled by an individual worker per minute) “by increasing job-specific staffing or decreasing job-specific line speed, may reduce musculoskeletal disorder risk for workers.”
The Trump Administration’s proposed rules do not require line speed increases be paired with staffing levels that allow piece rate to stay at a safer level for workers. But USDA’s justification for the rule uses the PULSE studies to claim that line speed increases won’t lead to an increase in injuries.
“USDA’s justifications for these line speed increase rules fundamentally distort key findings of our 2025 PULSE studies,” said Dr. Carisa Harris-Adamson and Dr. Robert Harrison. “The meat industry has been less willing than other sectors to voluntarily take steps to reduce worker injuries from repetitive, forceful motions. That makes it all the more important that federal health and safety regulations on this already dangerous type of work get it right. These proposed line speed increase rules do not get it right.”
“Meat processing workers across the U.S. are already suffering serious injuries at the line speeds currently permissible,” said Kelsey Eberly, FarmSTAND Senior Staff Attorney. “We’ve seen evidence that Big Ag varies its line speeds to privilege some groups of workers over others. These proposed rules allowing for line speed increases – built on USDA’s misrepresentations of careful research by Doctors Harris-Adamson and Harrison – would have the effect of giving industrial ag employers even more power over their workforce.”
FarmSTAND is a legal advocacy organization devoted to bringing about a fair food system for all, where everyone is able to work in conditions that are dignified, fair, and healthy.