Apr. 11, 2022 / Virginia Reyes
I. Introduction
Undocumented workers in animal agriculture face the highest level of environmental racism and injustice. They work in one of the most hazardous industries and belong to a vulnerable community that is Hispanic, low income, and undocumented. The legal structure that exists today through environmental and immigration law stimulates the exploitation of undocumented workers.
This paper will discuss undocumented workers in animal agriculture and focus on jobs throughout the industry. Animal agriculture is the concentrated mass production of meat, dairy, and eggs.[1] It is known as factory farming, also known as concentrated animal feeding operations (CAFO). These operations keep animals confined in small spaces with “feed, manure, urine, dead animals”[2] near both animals and workers. This paper will also discuss the heinous conditions in slaughterhouses for the workers themselves.
This paper exposes the exploitation of undocumented workers by the animal agriculture industry. Section II provides background on the National Environmental Policy Act (NEPA) and the Immigration Nationality Act (INA) legal structures affecting undocumented workers. Specifically, NEPA’s regulations mandating an Environmental Impact Statement (EIS) depicting the human impact of government actions such as operating CAFOs and INA structure for undocumented people in the United States to obtain legal status. Section III details animal agriculture’s environmental damage on the land, water, and air near animal agriculture facilities. Section IV lays out the devastating human health impacts of animal agriculture on the neighboring communities. Section V focuses on the atrocious effects undocumented workers endure in the animal agriculture industry. Section VI presents activism groups working with and providing resources for undocumented workers. Section VII displays the ineffective application of NEPA regulation on animal agriculture despite facing devastating human effects. Lastly, Section VIII illustrates INA’s inadequate avenues for undocumented workers to gain legal status in the United States. The paper concludes that the legal structures in place foster the environment that supports the exploiting undocumented workers.
II. Legal Structures
A. NEPA Regulation for Effects on the Human Environment
NEPA mandates the government to conduct an Environmental Impact Statement (EIS) when proposing federal action. An EIS is prepared when “a proposed major federal action is determined to significantly affect the quality of the human environment.”[3] Opening and operating a CAFO is a major federal action because it is funded and owned by the federal government. An EIS must include the following sections (1) a summary of the major conclusion, disputed issues, and the issues to be resolved, (2) purpose and need statement explaining why they are proposing the action and what they expect to achieve, (3) alternatives that can accomplish the purpose and need of the action, (4) affected environment with a description of the area to be affected and alternatives considered, (5) environmental consequences with a discussion of the effects and the significance, and (6) submitted alternatives, information and analyses from the state, tribal, and local governments for consideration during the scoping process or the final EIS.[4] The specific law that calls for an EIS and focuses on the human impact is 42 USC Code § 4332(2)(C). The law states all federal government agencies shall include a detailed statement by the responsible official that significantly affects the quality of the human environment.[5]
Agricultural corporations own the animals and control how and what the animals are fed or given antibiotics.[6] Few corporations manage most CAFOs in the United States. These corporations levy massive lobbying power in Congress to carve out enforcement gaps for CAFOs. The corporations have “worked to receive exemptions from noxious odors, greenhouse gas emissions, and solid waste discharges [and] . . . strategically favored placement and concentration of operations in states and counties where . . . environmental regulations are easily manipulated.”[7] These lax regulations by the government have a tricking effect that allows for the exploitation of undocumented workers discussed in depth in Section V.
B. INA Path for Lawful Status for Undocumented Workers
The Immigration Nationality Act governs the legal avenues for aliens to migrate into the United States. An alien is a “person who is not a citizen or national of the United States.”[8] There is no written legal definition for an illegal alien, nor does it explain who is an undocumented migrant. An undocumented person does not possess legal documentation to enter or remain in the United States. So, undocumented workers do not possess documentation to work in the United States legally. An alien cannot obtain a stand-alone work permit. They must have an accompanying immigration application pending or approved.[9]
An alien can gain lawful status through family-based or employment-based immigration. Generally, through family-based immigration, an alien applies for Adjustment of Status or Consular Processing after submitting the Form I-130, Petition for Alien Relative.[10] They need an immediate relative petitioner such as a spouse, parent, or child over 21 or other close relatives who is a legal permanent resident or citizen of the United States.[11] Adjustment of Status allows an alien to apply within the United States and requires the alien to have entered the United States lawfully or previously petitioned before April 31, 2001.[12] An alien can apply for Consular Processing if they are outside the United States and may need a qualifying relative such as a spouse or parent who is a legal permanent resident or a citizen of the United States.[13] Employment-based immigration is very similar to the processes described above, except the employer serves as the petitioner for both Adjustment of Status and Consular Processing. The employers submit the petition Form I-140, Immigrant Petition for Alien Worker.[14] The employer will need to show proof that “there are not sufficient workers who are able, willing, qualified . . . at the place where the alien is to perform such . . . labor.”[15]
The petitions submitted for both family or employment may be subject to the visa bulletin waiting times. There are annual limits for the number of visas available for people to gain lawful status in the United States. For family-based petitions, the limit depends on the preference, country, and priority date of their petition. The type of preferences of aliens subject to the visa bulletin waiting times are unmarried children of US citizens, spouse and children of legal permanent residents, married children of US citizens, and siblings of US citizens.[16] The countries with limits are China, India, Mexico, and the Philippines.[17] The dates are updated monthly to reflect the date applications that are currently based on the priority date their Form I-130 was filed. For employment-based applications, the preference that would pertain to factory farm workers is the third for certain special immigrants. This category is for skilled workers, professionals, and other workers.[18] The countries with limits are China, El Salvador, Guatemala, Honduras, India, Mexico, the Philippines, and Vietnam.[19] The visa availability is based on the priority date on their Form I-140 petition.
The Department of States uploads new dates for the visa bulletin every month. The current family-based category with the longest wait time is siblings of US citizens from Mexico with the current date as of December 2020 at April 22, 1999.[20] This is roughly a 21-year wait for people that submit applications this year. These long wait times are a barrier for people that do not have immediate relatives to petition them to gain lawful status.
The way the system is set up benefits those who already have ties to the United States. People that are seeking to migrate to the United States for the first time have a much harder time finding a path to gaining lawful status. These barriers explain why undocumented workers remain without lawful status because the system is so restrictive on who can apply for immigration benefits.
III. Environmental Pollution of Animal Agriculture
A. Water Pollution
CAFOs contaminate all water sources near the facilities. The facilities are known to store and discharge agricultural wastewater and land application of untreated animal waste that pollutes all waters in the area such as rivers, streams, and groundwater.[21] CAFOs are required to get a permit through the National Pollutant Discharge Elimination System (NPDES) permit program before they can discharge into any water source.[22] The number of CAFOs that do have NPDES permits is dangerously low for some states. The states with the most significant gaps are California with 1,083 total CAFOs and only 141 permits, Iowa with 3,744 total CAFOs and only 164 permits, and North Carolina with 1,222 total CAFOs and only 14 permits.[23] The reason so many CAFOs can produce so much pollution and are not required to have an NPDES permit is because of the exception created in the Clean Water Act (CWA). “Agricultural return flows and stormwater discharge are considered non-point sources and therefore do not require NPDES permits to discharge pollutants through these avenues. This exception to the Clean Water Act extends so far as to include rainwater that contacts stored manure and subsequently flows into navigable waters.”[24] The lagoons that hold wastewater can leach and rupture after heavy rainfall in the area and contaminate all water sources.[25] All the contaminants in these lagoons are spread out throughout the area and affect the communities in the vicinity.
The land application is the spraying of liquid waste onto fields usually surpassing the field’s nutrient needs and oversaturating them together with untreated waste, pathogens can survive contaminating nearby water sources including groundwater.[26] This runoff creates phosphorus contamination which stimulates the development of algal blooms and creates anoxic conditions with high levels of ammonia in water that kills fish in rivers and streams.[27] Polluting not only the aquatic life but the human life that relies on the groundwater.
B. Land Pollution
Oversaturation pollutes the land around CAFOs. Land application oversaturates the soil with macronutrients such as nitrates and pathogens as well as ammonium, phosphate, dissolved solids, metals and metalloids, pharmaceutical chemicals, and natural and synthetic hormones.[28] The soil can no longer absorb the nutrients so they leach into groundwater. The pathogens are “are parasites, bacterium, or viruses that are capable of causing disease or infection in animals or humans”[29] This pollution on the land is intertwined with the effects it has on water and air causing human health problems.
C. Air Pollution
Waste management releases chemicals into the air that harm the environment. Particulate matter is released into the air. Particulate matter is “comprised of fecal matter, feed materials, pollen, bacteria, fungi, skin cells, silicates.”[30] Causing the air quality to plummet around CAFOs. CAFOs are responsible for 75% of the United States’ ammonia air pollution.[31] Ammonia is formed when microbes decompose undigested organic nitrogen compounds in animal manure.[32] Ammonia is a “strong respiratory irritant” that causes chemical burns to the respiratory tract, skin, and eyes”[33] The odor of ammonia pollutes the air in the areas near and downstream from CAFOs causing a pungent rotten egg smell. Air can be so polluted that workers who entered lagoons succumbed to the emissions and some died from hydrogen sulfide poisoning or asphyxiation.[34] The air pollution is so dense and concentrated it has grim effects on the health of the people near CAFOs.
IV. Human Health Ramifications of Animal Agriculture
The people who disproportionately suffer the burden of pollution are Black, Hispanic, and Native-American low-income communities who live near CAFOs.[35]
Environmental pollution is the direct cause of the public health crisis communities face around CAFOs. The water pollution that contaminates the groundwater directly affects the health of the communities where roughly 53% use wells as their source for drinking water.[36] Pathogens are more likely to survive in groundwater because of the lower temperature and protection from the sun.[37] Drinking contaminated water with pathogens such as salmonellosis, cryptosporidiosis, giardiasis, and e-coli causes nausea, diarrhea and bloody diarrhea, vomiting, muscle pain, fever, kidney failures, and even death.[38] The water contains antibiotics that were widely fed to the animals so when humans drink the water they can ingest disease-resistant bacteria. As a result, the bacteria is impervious to antibiotics humans would take to treat the illness and can cause death.[39] These ailments come from drinking contaminated water alone.
The air pollution by CAFOs releases ammonia, hydrogen sulfide, and particulate matter into the air of these communities which bring a whole array of additional health consequences. Ammonia is a strong irritant that “causes chemical burns to the respiratory tract, skin, and eyes” as well as severe coughing and chronic lung disease.[40] Hydrogen sulfide causes inflammation of the moist membranes such as the eyes and respiratory tract and results in olfactory neuron loss, pulmonary edema, and possibly death.[41] Particulate matter causes “Chronic bronchitis, chronic respiratory symptoms, declines in lung function, organic dust toxic syndrome.”[42]
Children and immunocompromised adults are particularly more susceptible to the health impacts of CAFOs. Infants exposed to contaminated groundwater with nitrogen can cause “blue baby syndrome.”[43] It disrupts blood flow in infants which makes them appear blue because of the lack of oxygen. Adults with weak immune systems such as those with AIDS or those who receive cancer treatment are at a higher risk of contracting an illness from bacteria present in the contaminated groundwater.[44] Children are also more likely to develop asthma because of the area’s low air quality.
V. Focused Harm to Undocumented Workers
A. Demographics of Factory Farmworkers
Factory farms mostly employ undocumented workers. The agricultural sector employs more than 3 million migrant and seasonal workers and 72% of them are born outside the United States.[45] Many of the workers are Hispanic with 68% from Mexico and 3% from Central America (Honduras, El Salvador, Guatemala).[46] Around 35% and 27% could not speak English at all or a little respectively.[47] Many did not complete their education with 40% finishing between 1st to 6th grade with their average income ranging from $12,500 to $14,999.[48] Recent surveys of agricultural workers do not differential between crop and animal agriculture workers so it is difficult to calculate how many are undocumented today. A survey from 2007-2009 by the National Agricultural Workers Survey found that 48% of workers do not have legal authorization to work in the United States.[49]
Undocumented workers make up almost half of the workforce so they face most of the hardships industrial animal agricultural workers suffer. Most of the information presented shows the harsh human health conditions present in CAFOs. These workers are near all the pollutants emitted from CAFOs and face the harshest health problems.
B. Intensified Exposure and Effect on Physical and Mental Health
Occupational hazards present heightened exposure for workers. CAFO workers are 30% more likely to contract occupational asthma, acute and chronic bronchitis, and organic dust toxic syndrome because of the constant exposure to harmful emissions.[50] Exposure to particulate matter causes severe health issues where farm workers can develop acute and chronic bronchitis, chronic obstructive airways disease, and interstitial lung disease.[51]
For slaughterhouse workers, the effects are also psychological. Workers must disconnect from what they are doing to largely gentle creatures and perform their job duties. The “emotional dissonance . . . [leads] to consequences such as domestic violence, social withdrawal, anxiety, drug and alcohol abuse, and PTSD.”[52] The following study found Latino migrant workers had a significant association with alcohol dependence because of high levels of stress due to their “legality and logistics, mobile lifestyle, social isolation, and work conditions.”[53]
The intersectional identities of these workers create unhealthy living conditions. They are Hispanic, undocumented, low-income, uneducated, and lastly do not speak English. In the environmental justice context, they are the most vulnerable and susceptible to environmental racism. Being in a country that marginalizes and ignores them has disastrous outcomes. These workers are more likely to get sick but will likely not have the money to get treatment.
C. Worker Exploitation
Meatpacking corporations are likely to employ undocumented workers although the statistics are unclear. The majority of the workers obtain employment in these facilities because of friends and family recommendations.[54] Employers abuse their discretion for “at-will” employment and intimidate workers by reminding them they are replaceable.[55] These workers accept the hazardous and demeaning conditions because they are less likely to contest mistreatment or exercise their legal rights.[56]
Undocumented workers are the most vulnerable to exploitation because of their legal status, economic need, and language barrier. Workers do not feel they have the power to voice any concerns because of their legal status. This burden and almost shame they carry enables the employers to get away with exploitation since the workers will keep the complaints to themselves. They have a misconception that they need to have lawful status to have legal rights. These workers are mostly low-income with very little education. They do not feel as though they have options to find stable jobs so they do what they can to keep their jobs. One of the biggest challenges is the language barrier. Most workers speak Spanish so they cannot even verbally communicate their concerns to their employer. Considering the employers use tactics to intimate the workers it is not likely that they will take the time to find an interpreter or use their own resources to communicate with the workers. Even if the workers keep their heads down and do their work they can still be fired because the industry has such a high turnover rate. Undocumented workers are left to the discretion and will of their employers.
D. Working Conditions
Working conditions in meatpacking plants and slaughterhouses are deplorable. Workers are exposed to high noise levels, dangerous equipment, slippery floors, musculoskeletal disorders, hazardous chemicals such as ammonia.[57] Workers are also exposed to biological hazards while working with living animals such as feces and blood that increase their risk to contract a disease.[58] They work one of the most dangerous jobs where they must work on “slippery floors, perform repetitive motions for long hours, wield sharp knives and industrial saws, and process hundreds, if not thousands, of animals each day.”[59]
They are closely exposed to the pollutants in every step of industrial animal agriculture from the CAFOs to the meat packaging. The working conditions are especially horrid because they are repeatedly exposed to the chemicals in CAFOs from the wastewaters and feces of the animal they tend. In slaughterhouses, they are doused with more biological hazards when they cut open the animals. In meatpacking plants, they are constantly inhaling ammonia and have to meet high line speed. In every part of animal agriculture, these workers are exposed to harmful pollutants.
E. Workplace Injuries
Undocumented workers are more likely to under-report their work injuries. These workers are excepted to process thousands of animals per day. The past administration proposed a rule to increase line speeds during the COVID-19 pandemic. The production proposed to increase the line speed of birds from 140 birds per minute to 175 birds per minute.[60] The increase in production without a corresponding increase in workers will likely result in more injuries. Reports show that 65% of meatpacking workers have been injured on the job but Occupational Safety and Health Administration (OSHA) believes these numbers are underreported because undocumented workers are too fearful of retaliation to report an injury.[61] In recent years, undocumented workers have delivered astonishing numbers in animal agriculture production. In 2018, poultry meat production was approximately 9.3 billion pounds.[62] Last year, red meat production was approximately 4.57 billion pounds.[63] These workers are performing their duties despite the rampant risk of injuries. Workers will keep their injuries to themselves as long as they keep their employment.
The injuries undocumented workers suffer are gruesome and debilitating. Their fear keeps them from reporting their injury and they have to suffer the consequences alone. Since they are less likely to have health insurance they often do not treat their injuries if a hospital is not necessary. An increase in line speed will likely increase their demand and out of fear of retaliation they will do their work without complaining to their supervisors.
F. ICE and Undocumented Workers
Undocumented workers fear removal and employers use that information to threaten workers with reporting them to Immigration and Customs Enforcement (ICE). On August 7, 2019, the past administration ordered a sweep of immigration raids in a Mississippi chicken plant where 680 Hispanic workers were arrested.[64] The administration framed it as the partial fulfillment of their vow to remove millions of undocumented workers from the country.[65]
Xenophobia toward the Hispanic immigrant community demonstrated how the laws benefit those in power and keep undocumented workers marginalized. ICE is a federal agency under the control of the executive branch. The president and those in charge of the agency can enforce these raids to instill fear and deter the immigrant communities. Employers in plants constantly played with undocumented workers’ job security and replaced the workforce with African Americans after the raid.[66] The fear that ICE injects in undocumented workers revealed
VI. Advocacy for Undocumented Workers
Farm Worker Justice is a non-profit organization working to help advance the rights of migrant farmworkers. They help workers with their “immigration status, health, occupational safety, and access to justice.”[67] They work in Washington, CA where they can influence policy change directly and nationwide. Undocumented workers face more challenges than lawful migrant workers with work authorization or visas. This organization does the work to help all migrant workers in places where it will have a significant impact. They work with administrative agencies to improve labor protection laws, in courts where they help give a voice to a marginalized community, and in the public eye to educate about farmworker issues.[68] During the previous administration, there was a very prevalent xenophobic agenda against undocumented people in the United States. This organization is serving this community through policy change, legal access to justice, and positive public perception.
VII. Ineffective Application of NEPA regulation
NEPA’s ineffective application of its regulation to monitor the human health conditions at CAFOs has a catastrophic effect on undocumented workers. Because CAFOs produce massive numbers of animals they are creating the need for more workers down the processing chain of animal agriculture. The human health impacts are evident with CAFOs alone and increase to dangerous levels for undocumented workers that work to produce the final products such as meat, dairy, and eggs. NEPA needs to implement the EIS requirement and limited the operation and opening of new CAFOs. That could start to be a trickling effect that reduces the exploitation of undocumented workers. Reducing the amount of CAFOs would make a positive change in the industry to begin improving the environment and decrease human health effects.
VIII. Restrictive INA Regulations
There is not much data on how undocumented workers enter the United States. The INA applies differently depending on the set of conditions of each application presented before the United States Citizenship and Immigration Services (USCIS). Undocumented workers need to have relatives with status go through family-based immigration. For workers who are migrating to the United States for the first time do not have family ties in the United States. They can have a child in the United States and wait for the child to turn 21 to submit a petition but they still have to meet the qualifications to adjust their status. The workers would need to enter the United States legally with a visa but there is not much data on how they are entering the United States. These workers do not have the alternative route of applying based on a previous petition because they have no ties to the United States.
An undocumented worker cannot seek Consular Processing if they are applying through their child because they need a qualifying relative. They must have a spouse or a parent with lawful status and in the scenario described above t is not possible.
If they have other preferences of relatives laid out in Section II, B they may be subject to wait times. Considering a large portion of undocumented workers in animal agriculture are from Mexico they would be subject to the visa bulletin waiting times. They would not have an immediate path to lawful status.
Undocumented workers can also adjust their status through their employer but the same restrictions would apply here. They would need to enter the United States lawfully to qualify for Adjustment of Status. They would still need a qualifying relative to do Consular Processing if they have certain inadmissibilities.
INA’s specific requirements ultimately bar or restrict undocumented workers from obtaining lawful status. They cannot apply for a work permit unless they have an application pending. The initial petition for family-based or employment-based immigration does not grant them the right to apply for a work permit because it only establishes a relationship and not an immigration benefit. It is after the petition is granted and they have a visa available can they apply for Adjustment of Status and concurrently apply for a work permit while it is pending. For Consular Processing cases, they would not qualify for a work permit because they apply for this benefit outside the United States.
IX. Conclusion
Undocumented workers in animal agriculture are used and forgotten by the legal structures set in place. CAFOs enjoy the enforcement gaps from NEPA regulations that allow them to pollute the environment. Their waste management is lax which present serious health complications for the communities around these facilities. The undocumented workers interact with harmful pollutants at a closer range and risk more serious illnesses. They stay in these hazardous conditions whether it be CAFOs, slaughterhouses, or meat packaging plants because their lawful status causes their compliance and silence. The pathways to adjust status in the United States are filled with roadblocks and only allow for certain people to apply. Undocumented immigrants who do not know immigration law cannot navigate it on their own. They cannot easily gain lawful status in the United States so they stay hidden away in the margins. NEPA needs to comply with its own regulations and implement them to bring environmental justice to the communities and the undocumented workers. INA needs reform to allow more people to adjust their status and come out from the shadows of society. Undocumented workers help feed the United States and it is time we thank them.
Endnotes
[1] Environmental Racism, Food Empowerment Project, https://foodispower.org/environmental-and-global/environmental-racism/ (last visited Nov. 12, 2020).
[2] Animal Feeding Operations, USDA, https://www.nrcs.usda.gov/wps/portal/nrcs/main/national/plantsanimals/livestock/afo/ (last visited Nov. 20, 2020).
[3] National Environmental Policy Act Review Process, EPA (2020), https://www.epa.gov/nepa/national-environmental-policy-act-review-process#EIS (last visited Nov. 20, 2020).
[4] Id.
[5] Nat’l Envtl. Policy Act, 42 U.S.C. § 4332(2)(C).
[6] Symposium, Keeping It Fresh?: Exploring The Relationship Between Food Laws And Their Impact On Public Health And Safety: Article: “Yes, In Your Backyard!” Model Legislative Efforts To Prevent Communities From Excluding Cafos, 5 Wake Forest J. L. & Pol’y 147, 151 (2015).
[7] Daniel Imhoff et al., Myth: CAFOs Are Farms, Not Factories, CAFO The Tragedy of Industrial Animal Factories, http://www.cafothebook.org/thebook_myths_4.htm (last visited Nov. 23, 2020).
[8] 8 U.S.C. § 1101(a)(3).
[9] Employment Authorization Document, USCIS (2018), https://www.uscis.gov/green-card/green-card-processes-and-procedures/employment-authorization-document (last visited Nov. 20, 2020).
[10] Green Card for Family Preference Immigrants, USCIS (2020), https://www.uscis.gov/green-card/green-card-eligibility/green-card-for-family-preference-immigrants (last visited Nov. 20, 2020).
[11] 8 U.S.C. § 1151(b)(2)(A)(i).
[12] 8 C.F.R. § 245.
[13] Consular Processing, USCIS (2018), https://www.uscis.gov/green-card/green-card-processes-and-procedures/consular-processing (last visited Nov. 20, 2020).
[14] Green Card for Employment-Based Immigrants, USCIS, (2020), https://www.uscis.gov/green-card/green-card-eligibility/green-card-for-employment-based-immigrants (last visited Nov. 20, 2020).
[15] 8 U.S.C. § 1182 (5)(A)(i).
[16] Dep’t of State, Visa Bulletin for December 2020, Travel.state.gov (2020), https://travel.state.gov/content/travel/en/legal/visa-law0/visa-bulletin/2021/visa-bulletin-for-december-2020.html (last visited Nov. 20, 2020).
[17] Id.
[18] Id.
[19] Id.
[20] Id.
[21] Symposium, supra, at 152.
[22] Clean Water Act, 33 U.S.C. § 1342 (2012).
[23] Envtl. Prot. Agency, NPDES CAFO Permitting Status Report: National Summary, Endyear 2019, completed 07/20/20 (2020), https://www.epa.gov/sites/production/files/2020-08/documents/cafo_status_report_2019.pdf.
[24] Adam S. Carlesco, Hiding the Ball: The Sidestepping of National Pollution Discharge Elimination System Permitting Requirements by Concentrated Animal Feeding Operations, 5 J. Animal & Envtl. L. 43, 48 (2014).
[25] Symposium, supra, at 152.
[26] Id.
[27] Id.
[28] Christine Ball-Blakely, CAFOs: Plaguing North Carolina Communities Of Color, 18 Sustainable Dev. L. & Pol’y 4, 5 (2017).
[29] Carrie Hribar, Understanding Concentrated Animal Feeding Operations And Their Impact On Communities, 8 (2010), https://www.cdc.gov/nceh/ehs/docs/understanding_cafos_nalboh.pdf.
[30] Id. at 6.
[31] CAFOs Ordered to Report Hazardous Pollution, Waterkeeper Alliance (2017), http://waterkeeper.org/cafos-ordered-to-report-hazardous-pollution/.
[32] CAFO Subcomm. Of The Mich. Dep’t Of Envtl. And Toxics Steering Grp., Concentrated Animal Feedlot Operations (Cafos) Chemicals Associated With Air Emissions 1, 8 (2006), https://www.michigan.gov/documents/CAFOs-Chemicals_Associated_with_Air_Emissions_5-10-06_158862_7.pdf.
[33] Id. at 4.
[34] Ball-Blakely, supra, at 6.
[35] Id. at 5.
[36] Hribar, supra, at 3.
[37] Id. at 4.
[38] Id. at 10.
[39] Id.
[40] CAFO Subcomm., supra, at 4.
[41] Id. at 6.
[42] Hribar, supra, at 6.
[43] Envtl. Prot. Agency, Drinking Water From Household Wells, 1, 5 (2002), https://nepis.epa.gov/Exe/ZyPDF.cgi/200024OD.PDF?Dockey=200024OD.PDF
[44] Id.
[45] Nat’l Center for Farmworker Health, Inc., Demographics, (2012) http://www.ncfh.org/uploads/3/8/6/8/38685499/fs-facts_about_farmworkers.pdf (last visited Nov. 12, 2020)
[46] Id.
[47] Id.
[48] Id.
[49] Daniel Carroll et al., Changing Characteristics of U.S. Farm Workers: 21 Years of Findings from the National Agricultural Workers Survey, U.S. Dep’t of Labor, 14 (2011).
https://migrationfiles.ucdavis.edu/uploads/cf/files/2011-may/carroll-changing-characteristics.pdf
[50] Leo Horrigan et al., How Sustainable Agriculture Can Address the Environmental and Human Health Harms of Industrial Agriculture, 110 Environmental Health Perspectives 445–456, 451 (2002), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1240832/pdf/ehp0110-000445.pdf.
[51] Hribar, supra, at 6.
[52] The Psychological Damage of Slaughterhouse Work, PTSDJournal (2016), https://www.ptsdjournal.com/posts/the-psychological-damage-of-slaughterhouse-work/ (last visited Nov 25, 2020).
[53] Thomas A. Arcury et al., Alcohol Consumption and Risk for Dependence Among Male Latino Migrant Farmworkers Compared to Latino Nonfarmworkers in North Carolina. 40 Alcoholism, clinical and experimental research, 2 (2016).
[54] Nat’l Center, supra.
[55] Slaughterhouse Workers, Food Empowerment Project, https://foodispower.org/slaughterhouse-workers/ (last visited Nov. 25, 2020).
[56] Slaughterhouse Labor, Food & Power, https://www.foodandpower.net/slaughterhouse-labor#:~:text=Today%2C%20more%20than%20500%2C000%20people,people%20of%20color%20and%20immigrants. (last visited Nov. 25, 2020).
[57] U.S. Dep’t Of Labor, Meatpacking – Overview, Occupational Safety And Health Administration, https://www.osha.gov/meatpacking (last visited Nov. 25, 2020).
[58] Id.
[59] Food & Power, supra.
[60] Id.
[61] Id.
[62] National Agricultural Statistics Service, Poultry Slaughter 2018 Summary (2018).
[63] National Agricultural Statistics Service, Livestock Slaughter (2019).
[64] Richard Fausset, After ICE Raids, a Reckoning in Mississippi’s Chicken Country, The New York Times (2019), https://www.nytimes.com/2019/12/28/us/mississippi-ice-raids-poultry-plants.html (last visited Nov 12, 2020).
[65] Id.
[66] Id.
[67] About Farmworker Justice, Farmworker Justice, https://www.farmworkerjustice.org/about-farmworker-justice/ (last visited Nov 12, 2020).
[68] Id.