Both studies found a correlation between MSD risk and piece rate.
“There’s been so much attention on evisceration line speed, and our hope is that the conversation changes because that’s not the variable that’s going to help protect workers,” Harris said. “If we can talk about piece rate by area or by job, that would be a much more productive conversation to have.”
The two studies weren’t without limitations. One, as Harris called it, was “healthy worker survivor bias”—the tendency for results to reflect only workers healthy enough to continue on.
“Those who left employment due to work-related pain or the inability to keep up with the high pace of work were underrepresented,” the poultry report stated. The swine study echoed this limitation.
Debbie Berkowitz, who served as chief of staff at the Occupational Safety and Health Administration from 2009 to 2014, said she believes evaluated plants may have also added staff during the study period to reduce individual workloads while under observation.
“Because (the plants) knew they were being studied, they added workers to jobs, which meant that nobody was working harder and faster in the key jobs that they studied,” Berkowitz told Investigate Midwest.
The USDA spokesperson did not respond to a question about this phenomenon, but Harris acknowledged it was a concern—that plants may have temporarily improved working conditions during the study. However, she said her team regularly interviewed workers to assess whether the conditions they experienced during the studies matched their usual work environments. According to Harris, “very few” reported any differences.
Lori Stevermer, a Minnesota pork producer and immediate past president of the National Pork Producers Council, reiterated that “increased line speeds are not a leading factor in worker safety” in a statement to Investigate Midwest.
Super, of the National Chicken Council, said unsafe line speeds would be counterproductive for the industry itself.
“If line speeds are set too fast, then tasks will not be performed properly and the result will be a costly de-valuing of the final poultry products,” Super wrote in the statement. “No benefit exists for plant management to operate production lines at speeds that are unsafe, and will not permit all work to be performed at high levels of skill and competence.”
Where Efficiency Meets Animal Welfare
Slaughterhouse operations are systematic. Animals undergo a step-by-step process that stuns, scalds, removes organs, washes, cuts, and chills in a highly efficient fashion.
However, protocol can go awry for a variety of reasons, ranging from worker error to machinery malfunction. And animal welfare advocates allege that it has, especially at modernized swine and poultry plants with increasing line speeds and shifting federal oversight.
Delcianna Winders, director of the Animal Law and Policy Institute at the Vermont Law and Graduate School. (Photo courtesy of Delcianna Winders)
Delcianna Winders, director of the Animal Law and Policy Institute at the Vermont Law and Graduate School, said that faster line speeds result in more inhumane practices.
“Animals who are not keeping pace with the line are handled violently by workers who are just trying to keep up,” Winders told Investigate Midwest. This involves “increased dragging of animals, hitting of animals, and excessive electroshocking” leading up to slaughter, she said.
Concerns like these helped fuel a 2019 lawsuit filed by Winders and a group of animal welfare organizations, challenging the USDA’s swine modernization program. The lawsuit alleged, among other claims, that increasing line speeds and shifting responsibility from federal inspectors to slaughterhouse employees jeopardize humane handling.
“Even downed pigs—animals too sick or injured to walk—were handled in this way, because, according to a supervisor, they ‘don’t have time’ to handle them more humanely,” the lawsuit stated.
As part of the court case, advocates and inspectors submitted a series of declarations about personal experiences with modernization. One testimony came from Mauer, the consumer safety inspector who raised food safety concerns about her modernized pork plant in Austin, Minnesota.
Mauer wrote that on multiple occasions, she noticed pig carcasses with water-filled lungs from the scald tank—a stage in the slaughter process where animals should be dead.
“While there are a few reasons why tank water in the lungs may occur, tank water in hogs’ lungs is an indication that pigs were possibly still breathing at the time they entered the scalding tank,” her declaration stated.
Improper execution at slaughterhouses isn’t a new complaint. In 2013, the Washington Post reported that nearly 1 million birds were boiled alive in U.S. poultry plants every year, based on USDA data. This was in part due to rapid line speeds, which can result in unsuccessful slaughter prior to scald tank immersion, the article found.
But Super, of the National Chicken Council, maintained that modernization only changes the speeds of post-mortem evisceration lines. Leading up to and during slaughter, Super said, chicken processors consider animal welfare “the top priority,” and they “strictly adhere” to federal guidelines for humane handling.
Advocates remain critical. Michael Windsor—senior corporate engagement director at The Humane League, a nonprofit working to end farmed animal abuse—told Investigate Midwest in a statement that faster line speeds in any stage of processing add pressure to the entire system.
“Any increase in line speeds—pre- or post-mortem—create a dangerous ripple effect that increases suffering for animals and hazards for workers,” Windsor stated.
He added that consumers likely have a “limited sense” of what goes on behind closed doors at modernized plants.
“When people think about food safety or animal welfare, they don’t necessarily picture the exhausted workers racing to keep pace with hundreds of birds per minute or the animals being improperly stunned and boiled alive,” Windsor wrote. “This lack of awareness isn’t accidental. The meat industry operates in secrecy, and USDA policies—like allowing company employees to replace federal inspectors—only deepen the opacity.”
Four years after the 2019 lawsuit, the judge dismissed the case and upheld the federal swine modernization program. In a December 2023 ruling, the court found that FSIS had adequately considered humane handling impacts, which was all the law required.
Winders said she believes courts generally defer to the judgment of administration agencies like the USDA.
“It’s very hard to prevail against an agency because everything is going to be interpreted in their favor,” she said.
Winders and her team stand firm on one claim, arguing modernization reduces federal oversight and endangers animal welfare. They’ve appealed the ruling, and an oral argument is approaching in the next few months. With formal laws on the horizon, Winders said issues surrounding modernization are only growing more critical — not just due to risks to animals, but also to workers and consumers.
“It’s hard to disentangle the animal welfare concerns and human safety concerns,” she told Investigate Midwest. “They’re really intertwined.”
This article originally appeared at Investigate Midwest, and is reprinted with permission.

