Oklahoma Bar Journal
Why Oklahoma Should Care About USDA’s Pork Line-Speed Proposal: The Hidden Stakes of High-Speed Slaughter
By Will Lowrey and Emily Boden Torres
INTRODUCTION
“They use everything about the hog except the squeal.”
– Upton Sinclair, The Jungle (1906).
After Upton Sinclair’s 1906 novel, The Jungle, exposed the brutality and unsanitary conditions of Chicago’s early 20th century meatpacking industry, public distrust of industrial slaughterhouses helped spur the passage of the Federal Meat Inspection Act (FMIA).[i] More than a century later, regulators, advocacy groups, and the public are debating how fast the slaughter line can move before oversight itself begins struggling to keep pace. The current debate revolves around a pending USDA regulatory proposal that would accelerate the pace of modern pork slaughter while redefining the role federal inspectors play in keeping up with it.
While not as widely consumed in the United States as chicken and beef, Americans still enjoy pork, consuming roughly 50 pounds of the meat per person per year.[ii] In 2024, 130 million pigs were slaughtered in the United States, the majority of which were turned into pork products consumed domestically.[iii]
The slaughter of pigs for food and the subsequent inspection of their carcasses is regulated by the United States Department of Agriculture (USDA) under the FMIA, 21 U.S.C. §§601-695.[iv] The FMIA “requires that all meat sold commercially be inspected and passed to ensure that it is safe, wholesome, and properly labeled.”[v] To fulfill the congressional mandates of the FMIA, the USDA’s Food Safety and Inspection Service (FSIS) is tasked with providing on-site inspection services during slaughter operations.[vi] By law, FSIS inspectors are supposed to “verify the humane handling of animals and conduct antemortem inspection to ensure that the live animal is fit for slaughter.”[vii] The “humane handling” portion of this duty is done pursuant to the Humane Methods of Slaughter Act (HMSA), 7 U.S.C. §§1901-1907, a separate federal law whose enforcement is embedded within the FMIA.[viii] Under the FMIA, FSIS inspectors also “conduct post-mortem inspection to ensure that the meat from the carcass and internal organs are fit for human food.”[ix]
Combined, the FMIA and the HMSA aim to ensure that pork products are “wholesome, not adulterated” and “properly labeled”[x]; that “needless suffering” is prevented; that safer working conditions are created; and that products and economies are improved.[xi] As Congress plainly recognized in passing these laws, the modern slaughterhouse sits at the confluence of important issues relating to food safety, worker safety, environmental protection, and animal welfare.
These issues are particularly important for Oklahomans to consider. In Guymon, Seaboard Foods operates one of the largest pork processing plants in all the United States: a 900,000 square-foot facility.[xii] The plant has operated at full capacity since 1997[xiii] and currently employs nearly 3,000 workers.[xiv] Workers there slaughter over 20,000 pigs per day (over 5 million pigs per year),[xv] producing 1.4 billion pounds of pork annually.[xvi] As FSIS decides whether to allow pig slaughterhouses like Guymon’s Seaboard Foods plant to operate at even higher rates of slaughter, it behooves Oklahomans to appreciate the various issues that have arisen in this contentious administrative debate.
THE PROPOSED RULE AND ITS HISTORY
In the early 1990s, concern regarding foodborne illnesses increased.[xvii] In response, the FSIS applied a preexisting framework called the Hazard Analysis and Critical Control Point (HACCP) program to meat and poultry slaughterhouses, requiring establishments to take affirmative steps to reduce risk.[xviii] In 1997, the FSIS created a pilot program for five pork processing plants, called the HACCP-Based Inspection Models Project (HIMP), to “test and evaluate new approaches to fulfilling inspection requirements by plants and FSIS inspectors.”[xix] The HIMP pilots changed how inspection occurred, including by reducing the number of federal inspectors, tasking plant employees with certain tasks rather than inspectors, and allowing higher line speeds.[xx] The U.S. Government Accountability Office (GAO) and USDA’s Office of Inspector General (USDA OIG) identified several problems with the programs, including gaps in FSIS’s evaluation of the potential negative impact on food safety, worker safety, and the agency’s humane handling obligations.[xxi] The GAO flagged that FSIS had failed to complete a final report evaluating the programs, and that its preliminary report was lacking, in part because “FSIS did not collect comparable data from plants participating and not participating in the pilot project” and due to the small sample size of just five plants.[xxii] A year later, after FSIS responded, the GAO considered the agency to have “generally fulfilled the intent” of its recommendations by “generally address[ing]” the program’s limitations and creating a final evaluation report for the program.[xxiii]
In February 2018, FSIS proposed a new rule, which extended many of the elements of HIMP, but went a step further by proposing to remove line speed limits at participating facilities altogether and allow those facilities to set their own maximum speeds.[xxiv] This program, the New Swine Slaughter Inspection System (NSIS), was open for participation to any qualifying establishments, no longer limited to the original five HIMP plants.[xxv] In March 2019, 16 members of Congress sent a letter to the USDA OIG expressing concern, specifically regarding FSIS’s worker safety analysis underlying the proposed rule.[xxvi] FSIS finalized the rule in October 2019.[xxvii]
Immediately following finalization of the rule, the United Food and Commercial Workers International Union (UFCW) sued FSIS.[xxviii] While the case was ongoing, USDA OIG issued a report addressing the concerns raised by the members of Congress, finding several inadequacies with the rule, including that “FSIS did not take adequate steps to determine whether the worker safety data it used for the proposed rule were reliable.”[xxix] FSIS responded to the report, but the USDA OIG only accepted its answers to two of the four recommendations it had made to the agency.[xxx] In January 2020, Food & Water Watch and the Center for Food Safety also sued FSIS, alleging the rule violated the FMIA and was arbitrary and capricious, but were ultimately unsuccessful.[xxxi]
In 2021, the U.S. District Court for the District of Minnesota, in the UFCW’s case, vacated the portion of the final rule that removed line speed limits altogether.[xxxii] The court’s decision was based, in part, on its finding that despite FSIS identifying worker safety concerns as an important consideration and receiving many comments on the proposed rule about that issue, the agency “rejected the comments and eliminated line speed limits without considering worker safety.”[xxxiii] In 2022, through collaboration with the Occupational Safety and Health Administration (OSHA), FSIS began a so-called Time-Limited Trial (TLT) where six of the existing NSIS program slaughterhouses received a “regulatory waiver in order to experiment with ergonomics, automation, and crewing to design custom work environments that protect food safety and establishment worker safety while increasing productivity.”[xxxiv] That same year, the agency commissioned the Swine Processing Line Speed Evaluation Study (the PULSE Study), in which researchers from the University of California – San Francisco studied the impact of line speeds on worker safety.[xxxv] In 2024, FSIS announced it would modify the TLT program to collect data on worker safety.[xxxvi] In 2025, the results of the PULSE Study were finalized.[xxxvii]
This past February, FSIS issued a new proposed rule related to swine slaughter line speeds.[xxxviii] Despite the previous judicial intervention, FSIS again proposes to remove line speed limits entirely and allow participating pork processing plants to set their own maximums.[xxxix] This time, the proposed rule would also remove the requirement that slaughterhouses submit worker safety attestations to FSIS and end the TLT waiver conditions while retaining baseline microbiological sampling requirements.[xl] There is significant public interest in the current rulemaking; FSIS received over 60,000 public comments on the proposed rule.[xli]
ASSOCIATED ISSUES
Animal Welfare Concerns
The current proposed rule has stirred vigorous debate regarding animal welfare implications that arise from speeding up slaughter lines at pork plants. On one side, FSIS and representatives of the pork industry argue that the evidence does not reflect any risk of increased welfare issues. On the other side, animal protection advocates and others have sounded the alarm that pigs sent to slaughter will be subjected to increased risks of inhumane handling as workers try to keep up with likely increased rates of slaughter under the rule.
FSIS’s arguments take several forms. First, the agency argues that nothing in the proposed line speeds rule eliminates the requirements of the HMSA, and participating plants are still bound to comply with the same humane handling laws.[xlii] FSIS argues that transitioning some responsibilities to plant workers will make inspectors more available to “effectively verify establishments' compliance with humane handling requirements.”[xliii] The agency asserts that its inspectors still have final authority and remain empowered to take action by slowing line speeds in the event the plant cannot maintain process control.[xliv]
FSIS also relies heavily on data from the TLT, claiming that it shows the subject plants were “able to handle livestock in a humane manner.”[xlv] To bolster this claim, the agency says the TLT did not document “any incidents of market hogs slipping or falling, which indicates that no animals at TLT establishments were forced to move faster than normal walking speeds in an effort to maintain increased line speeds.”[xlvi]
But not everyone agrees with FSIS’s view. On April 20, 2026, dozens of animal protection, environmental advocacy, and labor rights groups submitted joint comments that strongly oppose the proposed rule, citing significant animal welfare concerns, along with environmental, food safety, and worker safety issues.[xlvii] With regard to animal welfare, the comments took issue with FSIS’s “narrow” analysis of the TLT data, stating that it ignores many documented humane handling issues at slaughter plants that did not partake in the TLT and “which are likely to increase their line speeds if the Proposed Rule is finalized.”[xlviii] Specifically, the comments referenced incidents involving individuals dragging disabled pigs, striking pigs with gates to force them to move, hitting pigs in the head and face with paddles and bats, depriving animals of water, crowding them in pens, or failing to properly stun pigs before cutting their throats.[xlix] The comments also disputed FSIS’s reliance on TLT data, which came from just six plants, due to wide variations in plant design, the fact that the plants were selected in part because they had not had humane handling enforcement actions in the past 120 days, and the “chronic inspector staffing shortages” of FSIS inspectors which resulted in less observation of inhumane handling.[l]
The advocacy groups also criticized the proposed rule for failing to include requirements of adequate training of plant employees and facility redesign to handle a greater number of pigs being slaughtered.[li] Finally, the groups pointed to undercover investigations conducted at pig slaughter plants that revealed inhumane handling, including a 2015 investigation at a plant in Minnesota operating under increased line speeds.[lii] The comments pointed out that workers at the plant who “were under pressure to keep up” with increased line speeds “dragged, kicked, beat, and excessively shocked pigs with electric prods to try to get them to move faster”; “disabled pigs were driven by excessive force in an effort to move them more quickly”; and there were “many instances of improper stunning of pigs, where pigs showing signs of consciousness had their throats slit.”[liii]
Environmental Concerns
Another area of controversy surrounding the proposed rule is related to how the rule may negatively impact the environment. Slaughterhouses produce several different kinds of waste, including liquids like blood, urine, and wastewater, and solids like bones, organs, and skin.[liv] Once slaughtered, approximately 60-62% of each pig’s body is utilized for meat, while the remaining 38-40% is either rendered into other products or directly disposed of.[lv] Studies show, and the Environmental Protection Agency has confirmed, that this waste can harm the environment, primarily due to its numerous harmful components, including heavy metals, nitrogen, phosphorus, ammonia, chlorides, biochemical oxygen demand, E. coli, and drugs that were in an animal’s system at the time of slaughter.[lvi] For example, when liquid slaughterhouse waste enters nearby surface waters, it can cause phenomena like oxygen depletion, algal blooms, and harmful nutrient enrichment, killing fish and disrupting the ecosystem.[lvii] When humans are exposed to water contaminated by slaughterhouse waste via swimming, drinking, or irrigating their lawns, they can develop harmful health impacts.[lviii] Waste from these facilities can also degrade air quality; when discharged onto fields via sprinklers, for example, particles enter the air and can cause serious human health issues, such as asthma and autoimmune disorders.[lix]
In the proposed rule, FSIS says it “does not anticipate that increasing the line speed may have a significant environmental effect.”[lx] The agency supports its conclusion by saying that allowing faster line speeds “would not affect consumer demand for the establishments’ products” and that the facilities would still need to adhere to federal, state, and local environmental requirements.[lxi]
It is true that even if line speeds increase, the total number of animals slaughtered might not because, hypothetically, plants could move their lines at faster speeds but run them for fewer hours, thereby processing the same number of animals as before. The proposed rule repeatedly says that it is designed to increase the “efficiency” of pork slaughter;[lxii] it does not explicitly say it is intended to allow those establishments to process more pork. However, the proposed rule’s Preliminary Regulatory Impact Analyses (PRIAs) contain economic modeling, which assumes increased production, suggesting that FSIS actually does anticipate the amount of pigs slaughtered to increase.[lxiii] In any event, it is possible that plants would slaughter more animals if line speed limits were removed under this proposed rule, and it is worth considering the environmental impacts of that possibility.
Worker Safety Concerns
Work in the slaughter industry is dangerous.[lxiv] Workers on the slaughter line often use sharp tools and handle heavy carcasses or body parts.[lxv] They are usually stationed in one spot on the processing line and perform a single task over and over again.[lxvi] Compounding these repetitive movements is a slaughterhouse facility’s typically cold environment, which can reduce a worker’s dexterity and limit blood flow.[lxvii] Performing these same motions many times per day at a rapid pace, combined with the cold conditions, commonly leads slaughterhouse workers to develop a number of serious musculoskeletal problems, including carpal tunnel syndrome and tendonitis.[lxviii] According to a Centers for Disease Control (CDC) National Institute for Occupational Safety and Health (NIOSH) report on worker safety at a pork slaughterhouse in Michigan, musculoskeletal disorders (MSDs) “can cause chronic pain and make moving painful or harder to do.”[lxix] The PULSE Study itself found that 46% of pork slaughterhouse workers who participated were at high risk for MSDs.[lxx] OSHA has consistently acknowledged that slaughterhouse workers are exposed to serious dangers and issued guidance related to preventing, among other things, cumulative trauma disorders.[lxxi] Other federal agencies have similarly found meatpacking to be extremely dangerous and that it can be much more dangerous than other types of industrial work in the United States.[lxxii]
The proposed rule would remove the requirement that NSIS slaughterhouses submit attestations regarding worker safety.[lxxiii] To support this change, FSIS emphasizes that a separate federal agency, OSHA, is responsible for worker safety, not FSIS.[lxxiv] Furthermore, the agency points out that the proposed rule would only allow facilities to set their own line speeds if they maintain “process control” and that the TLT found that they could do so successfully.[lxxv] Worker safety at a processing plant is related to many factors, not just line speeds (for example, staffing density: If line speeds increase but an establishment hires more workers, the number of repetitive motions an individual makes may not increase).[lxxvi] FSIS relies heavily on the PULSE Study, saying it found no negative risk of musculoskeletal disorders when line speeds increased.[lxxvii]
The agency’s assertion that it does not have statutory authority over worker safety is a contested one, especially given worker safety concerns historically raised (as noted above) by the GAO, USDA OIG, and federal court in UFCW’s case, related to FSIS’s regulation of pig slaughter. As demonstrated by the joint comments submitted by advocacy groups highlighted above, the proposed rule may significantly impact worker safety.[lxxviii] FSIS’s reliance on the PULSE Study results may be called into question by the fact that the researchers clearly linked increased staffing to reduced MSD risk even with higher line speeds,[lxxix] yet there are no mandatory staffing levels required for setting your own maximums under the proposed rule. The slaughter industry has been facing a labor shortage for several years.[lxxx] If line speeds do increase without robust increases in staffing, advocates argue that it is likely pork processing plant workers would have to make more repetitive motions faster, thereby further exacerbating existing injury potential.
CONCLUSION
Ultimately, the debate surrounding FSIS’s proposed pig line speeds rule reflects broader questions about how the United States government balances efficiency in industrial food production with worker safety, animal welfare, and environmental stewardship. For Oklahoma, home to one of the nation’s largest pork processing facilities, these issues are not abstract policy questions but matters with real implications for workers, rural communities, consumers, the environment, and animals alike.
ABOUT THE AUTHORS
Will Lowrey is legal counsel for Animal Partisan, a national nonprofit animal protection organization. He has engaged in numerous lawsuits, as well as criminal and administrative enforcement actions against the government and private parties on matters spanning federal slaughter laws, public records, false advertising, nuisance, and animal cruelty. He has taught animal law at law schools around the country and currently teaches the course as an adjunct professor at the OU College of Law.
Emily Boden Torres is a staff attorney at Animal Partisan, a national nonprofit animal protection organization. Ms. Torres graduated from Lewis & Clark Law School in 2024 with certificates in Environmental & Natural Resources Law and Animal Law. She is active in the American Bar Association’s TIPS Animal Law Committee, including by serving as Co-Chair of its Animals in Agriculture subcommittee. She is also a member of her local bar association’s Animal Law Committee.
ENDNOTES
[i] Christopher Klein, “How Upton Sinclair’s ‘The Jungle’ Led to US Food Safety Reforms,” History (last updated May 27, 2025), https://bit.ly/4bnMvEX.
[ii] U.S. Dept. of Agriculture, LDP-M-372, “Livestock, Dairy, and Poultry Outlook: June 2025” at 21 (June 18, 2025), https://bit.ly/4fBuQw7.
[iii] National Agriculture Statistics Services, “U.S. Dep’t of Agric., Livestock Slaughter: 2024 Summary” (Apr. 2025), https://bit.ly/4fMJQGh.
[iv] 21 U.S.C. §§602-693.
[v] Food Safety and Inspection Services, U.S. Dept. of Agriculture, “Summary of Federal Inspection Requirements for Meat Products” (revised Sept. 2015), https://bit.ly/4z1ZTJ9.
[vi] Id.
[vii] Id.
[viii] 7 U.S.C. §§1901-07.
[ix] Id.
[x] 21 U.S.C. §602.
[xi] 7 U.S.C. §1901.
[xii] “Our Connected System,” Seaboard Foods, https://bit.ly/4xlBJaT (last visited May 26, 2026). Note that this article uses the terms “processing plant,” “slaughterhouse,” and “establishment” interchangeably.
[xiii] “Our History: A Legacy of Quality and Innovation,” Seaboard Foods, https://bit.ly/3RPKpXQ (last visited May 26, 2026).
[xiv] “Facts and Figures,” Seaboard Foods, https://bit.ly/4w01AE1 (last visited May 26, 2026).
[xv] “Our History: A Legacy of Quality and Innovation,” supra note 13; “Seaboard Foods celebrates 25 years of producing quality pork,” Seaboard Foods (Dec. 15, 2020), https://bit.ly/4w3yt2A.
[xvi] Id.
[xvii] See, e.g., 48 Ctrs. for Disease Control & Prevention “Morbidity & Mortality Wkly. Rep.” 905 (Oct. 15, 1999), https://bit.ly/4537VDS (“In 1993, a severe outbreak of E. coli O157:H7 infections attributed to consumption of undercooked ground beef resulted in 501 cases of illness, 151 hospitalizations, and three deaths, and led to a restructuring of the meat inspection process.”).
[xviii] “Pathogen Reduction; Hazard Analysis and Critical Control Point (HACCP) Systems,” 61 Fed. Reg. 38806 (July 25, 1996) (codified at 9 C.F.R. pts. 304, 308, 310, 320, 327, 381, 416, 417).
[xix] “HACCP-Based Meat and Poultry Inspection Concepts: In-Plant Slaughter Inspection Models Study Plan,” 63 Fed. Reg. 40381 (proposed July 29, 1998) (to be codified at 9 C.F.R. pts. 309, 310, 381, 417). Note that there was never a final rule published by FSIS for the swine-specific HIMP program.
[xx] “HACCP-Based Inspection Models Project,” Food Safety & Inspection Services, U.S. Dept.of Agriculture, https://bit.ly/4wQWXxj (last updated Jan. 24, 2024). Note that FSIS issued HIMP performance standards in 2000. HACCP-Based Inspection Models Project (HIMP): Performance Standards for Young Turkey, Young Chicken, and Market Hog HIMP Plants, 65 Fed. Reg. 65828 (Nov. 2, 2000).
[xxi] U.S. Govt. Accountability Office, GAO-13-775, “Food Safety: More Disclosure and Data Needed to Clarify Impact of Changes to Poultry and Hog Slaughter Inspections,” 10-14 (Aug. 22, 2013), https://bit.ly/4bET0TX (“...faster line speeds allowed under the pilot projects raise concerns about food safety and worker safety”); Office of Inspector Gen., U.S. Dept. of Agriculture, Audit Rep. 24601-0001-41, “Food Safety and Inspection Service – Inspection and Enforcement Activities at Swine Slaughter Plants,” 217–22 (May 2013), https://bit.ly/3REoNha.
[xxii] GAO-13-775, supra note 21, at 10-14 (Aug. 22, 2013), https://bit.ly/4wMjxXP.
[xxiii] Id. (See “Recommendations for Executive Action” table at bottom of page). FSIS completed its evaluation of HIMP for Market Hogs in response to the reports issued by GAO and USDA OIG. Food Safety & Inspection Services, U.S. Dept. of Agriculture, “Evaluation of HACCP Inspection Models Project (HIMP) for Market Hogs: Final Report,” (Nov. 2014), https://bit.ly/45RIbul.
[xxiv] “Modernization of Swine Slaughter Inspection,” 83 Fed. Reg. 4780 (Feb. 1, 2018) (to be codified at 9 C.F.R. pts. 301, 309, 310).
[xxv] Modernization of Swine Slaughter Inspection, 83 Fed. Reg. at 4780.
[xxvi] Office of Inspector Gen., U.S. Dept. of Agriculture, Insp. Rep. 24801-0001-41, “FSIS Rulemaking Process for the Proposed Rule on the Modernization of Swine Slaughter Inspection,” (June 2020), https://bit.ly/4g8w4xI (“On March 26, 2019, 16 members of Congress sent a formal request to USDA’s Office of Inspector General (OIG) to review USDA’s rulemaking process related to the proposed rules’ worker safety analysis.”). Several months later, two members of Congress requested that the USDA OIG expand the initial inquiry. See Letter from Rosa L. DeLauro, Member of Congress, and Jeffrey A. Merkley, U.S. Sen., to the Honorable Phyllis K. Fong, Inspector Gen., U.S. Dept. of Agriculture. (Aug. 1, 2019).
[xxvii] “Modernization of Swine Slaughter Inspection,” 84 Fed. Reg. 52300 (Oct. 1, 2019) (codified at 9 C.F.R. pts. 301, 309, 310).
[xxviii] United Food & Commercial Workers Union, Local No. 663 v. United States Dept. of Agriculture, 532 F. Supp. 3d 741 (D. Minn., Mar. 31, 2021).
[xxix] Insp. Rep. 24801-0001-41, supra note 26.
[xxx] Id.
[xxxi] Ctr. for Food Safety v. Perdue, 2022 U.S. Dist. LEXIS 179135* (N.D. Cal. Sept. 30, 2022).
[xxxii] United Food & Commercial Workers Union, 532 F. Supp. 3d at 782.
[xxxiii] Id. at 749 (“The agency’s rejection of worker safety concerns is not merely a technicality. It had wide-reaching implications for workers and pork plant operators. Many of these stakeholders submitted comments directly addressing the issue.”).
[xxxiv] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7906.
[xxxv] Carisa Harris-Adamson, et al., “Swine Processing Line Speed Evaluation Study,” (Jan. 10, 2025), https://bit.ly/3SuQbOP (hereinafter PULSE Study).
[xxxvi] “Special Alert: Constituent Update – February 27, 2024,” Food Safety & Inspection Services, U.S. Dept. of Agriculture, https://bit.ly/4wVFBPZ.
[xxxvii] PULSE Study, supra note 35.
[xxxviii] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7905.
[xxxix] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7905.
[xl] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7905. Note that in May 2026, FSIS finalized a separate rule which will require inspectors to (primarily) only visually inspect pigs post-mortem, rather than manually inspecting them as is currently required. Visual Post-Mortem Inspection in Swine Slaughter Establishments, 91 Fed. Reg. 29879 (May 21, 2026) (codified at 9 C.F.R. pt. 310).
[xli] “Maximum Line Speed under the New Swine Slaughter Inspection System,” Regulations.gov, https://bit.ly/3SaLR7l (See “Comments Received” on the lefthand side.). Note that comments are counted in two ways: the number of submissions, and the number of total comments received (one submission can contain multiple comments). “Frequently Asked Questions,” Regulations.gov, https://bit.ly/4zfAATI (last visited May 27, 2026) (Expand “How are Comments counted and posted to Regulations.gov?”). 61,148 was the total number of comments received.
[xlii] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7911.
[xliii] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7911.
[xliv] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7913 (“FSIS retains the ability to slow line speeds should those speeds not allow FSIS to ensure that process control is maintained or that FSIS can perform an effective carcass-by-carcass inspection as required by law.”).
[xlv] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7911.
[xlvi] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7911.
[xlvii] Animal Law and Policy Institute, et al., Comment Letter on Proposed Rule: Maximum Line Speed under the New Swine Slaughter Inspection System 32 (Apr. 21, 2026), https://www.regulations.gov/comment/FSIS-2025-0009-37525 [hereinafter Coalition Comment].
[xlviii] Id. at 32.
[xlix] Id. at 38-42.
[l] Id. at 32.
[li] Id. at 33.
[lii] Id. at 33, 45.
[liii] Id. at 45.
[liv] See, e.g., Velusamy Mozhiarasi and Thillai Sivakumar Natarajan, “Slaughterhouse and poultry wastes: management practices, feedstocks for renewable energy production, and recovery of value added products,” 15 Biomass Conversion and Biorefinery 1708 (2025); Ravshanbek S. Alibekov et al., “Review of the slaughter wastes and the meat by-products recycling opportunities,” Frontiers in Sustainable Food Systems at 6 (July 10, 2024); Dennis Ashilenje, et al., “A Literature Review of Slaughterhouse Waste Valorisation: Techniques, Environmental, and Economic Implications,” 224 Resources, Conservation & Recycling 2 (2026).
[lv] See, e.g., Mozhiarasi & Natarajan, supra note 54, at 1705, 1706.
[lvi] Id. at 1710; Maximilian Philipp, et al., “Slaughterhouse Wastewater Treatment: A Review on Recycling and Reuse Possibilities,” 13 Water 3175 at 6 (2021); Ciro Bustillo-Lecompte & Mehrab Mehrvar, “Slaughterhouse Wastewater: Treatment, Management and Resource Recovery” in Physico-Chemical Wastewater Treatment and Resource Recovery 155 (ed. Zaki Adhmad Robina Farooq, 2017) (“Meat processing effluents are considered harmful worldwide due to the SWW complex composition of fats, proteins, fibers, high organic content, pathogens, and pharmaceuticals for veterinary purposes.”). See also, Office of Water, Envtl. Prot. Agency, EPA-821-R-23-012, “Environmental Assessment for Revisions to the Effluent Limitations Guidelines and Standards for the Meat and Poultry Products Point Source Category” 2-2 (Dec. 11, 2023), https://bit.ly/4grG5Y6.
[lvii] See, e.g., Mozhiarisi & Natarajan, supra note 54, at 1710; Bustillo-Lecompte & Mehrvar, supra note 56, at 157; EPA-821-R-23-012, supra note 56, at 2-5, 2-6.
[lviii] Bustillo-Lecompte & Mehrvar, supra note 56, at 157. For example, ingestion of water containing heavy metals that originate from slaughterhouse waste can cause humans to develop mental disorders. See Mozhiarisi & Natarajan, supra note 54, at 1710; EPA-821-R-23-012, supra note 56, at 2-9, 2-10, 5-1 to 5-4.
[lix] See, e.g., Delcianna J. Winders & Elan Abrell, “Slaughterhouse Workers, Animals, and the Environment: The Need for a Rights-Centered Regulatory Framework in the United Sates That Recognizes Interconnected Interests,” 23 Health and Human Rights J. 21, 24 (Dec. 2021); EPA-821-R-23-012, supra note 56, at 2-13, 2-14.
[lx] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7905. Based on this first conclusion, the agency secondarily concluded that the action is categorically excluded from requiring an environmental impact analysis under the National Environmental Policy Act (NEPA). Id.
[lxi] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7925.
[lxii] See, e.g., Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7913, 7914, 7918-19.
[lxiii] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7919. Regulatory Impact Analyses weigh the costs and benefits of a proposed regulation, and are required when that proposed regulation is expected to have significant economic impacts. See, e.g., Maeve P. Carey, “Cost-Benefit Analysis in Federal Agency Rulemaking,” Congressional Research Serv. (Oct. 28, 2024), https://bit.ly/4gtMZw0.
[lxiv] See, e.g., Sean M. Smith, “How safe are the workers who process our food?” U.S. Bureau of Labor Statistics (July 2017), https://bit.ly/4zwM5GT.
[lxv] See, e.g., Nat’l Inst. for Occupational Safety & Health, Ctrs. for Disease Control & Prevention, HHE Report No. 2021-0117-3397, “Evaluation of Ergonomic Risks, Musculoskeletal Disorders, and Peracetic Acid Exposure Among Employees at a Pork Processing Plant in Michigan,” 4 (Apr. 2024), https://bit.ly/4zaEWvD; Gov’t Accountability Office, GAO-16-337, “Workplace Safety and Health: Additional Data Needed to Address Continued Hazards in the Meat and Poultry Industry,” 27 (Apr. 2016), https://www.porgwebnidta.com/assets/680/676796.pdf; Occupational Safety and Health Administration, Opinion Letter on Inspection Guidance for Animal Slaughtering and Processing Establishments (Oct. 15, 2024), https://bit.ly/4fUWt3p [hereinafter OSHA Inspection Guidance 2024].
[lxvi] See, e.g., GAO-16-337, supra note 65, at 6.
[lxvii] See generally Adriana Seára Tirioni, et al., Thermographic Evaluation of the Hands of Pig Slaughterhouse Workers Exposed to Cold Temperatures, 14 International Journal of Environmental Research and Public Health 838 (July 26, 2017), https://bit.ly/3U9mTpp. See also GAO-16-337, supra note 65, at 30.
[lxviii] See, e.g., PULSE Study, supra note 35, at 9, 11, 74.
[lxix] HHE Report No. 2021-0117-3397, supra note 65, at 4.
[lxx] PULSE Study, supra note 35, at 6.
[lxxi] See, e.g., OSHA Inspection Guidance 2024 supra note 65; Occupational Safety and Health Administration, OSHA 3123, “Ergonomics Program Management Guidelines for Meatpacking Plants” (Reprinted 1993), https://bit.ly/4hvfYRk; “Occupational Safety & Health Admin.: Safety and Health Guide for the Meatpacking Industry,” OSHA 3108 (1988), https://bit.ly/4wn8WS6.
[lxxii] See, e.g., Sean M. Smith, supra note 64 (finding that in 2015, the rate of injury and illness among meatpacking workers was higher than “for all manufacturing and for all private industry.”); U.S. Govt. Accountability Office, GAO-05-96, “Safety in the Meat and Poultry Industry, While Improving, Could Be Further Strengthened,” (2005), https://bit.ly/4g2mHj6. Although not a formal agency publication, see also Carol Conroy, “Work-Related Injuries in the Meatpacking Industry,” J. of Safety Research (1989), https://bit.ly/4fV7hyt, which was authored by a CDC epidemiologist and based upon NIOSH data.
[lxxiii] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7912.
[lxxiv] See, e.g., Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7912 (“OSHA, not FSIS, is the Federal agency responsible for establishment worker safety issues.”), 7913 (“OSHA is the Federal agency with statutory authority to promote workplace safety and health.”).
[lxxv] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7912.
[lxxvi] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7909.
[lxxvii] Maximum Line Speed Under the New Swine Slaughter Inspection System, 91 Fed. Reg. at 7909.
[lxxviii] Coalition Comment, supra note 47, at 48-52.
[lxxix] PULSE Study, supra note 35, at 8.
[lxxx] See, e.g., “Labor Dilemma: A Force to Reckon With,” MEAT+POULTRY (Apr. 23, 2024), https://bit.ly/4fRJ5gm.
Originally published in the Oklahoma Bar Journal – OBJ 97 No. 7 (September 2026)
Statements or opinions expressed in the Oklahoma Bar Journal are those of the authors and do not necessarily reflect those of the Oklahoma Bar Association, its officers, Board of Governors, Board of Editors or staff.