Industry's opposition to the proposed interpretation centers on the fact the interpretation will have a disparate impact on employers based solely on their economic condition and not on the hazards to which their workers are exposed. The interpretation may also impose substantial additional costs on employers without producing a commensurate benefit to employees.
Comments were prepared by the Joint Poultry Industry Safety & Health Council, which is made up of members from US Poultry & Egg Association, National Chicken Council and National Turkey Federation. Collectively, the three organizations represent companies that produce 95% of the nation's poultry products and employ hundreds of thousands of workers.
Details regarding the comments can be viewed on US Poultry & Egg Association's website.