The diversity of the United States workforce has increased significantly over the past several decades. According to the U.S. Census Bureau, the estimated number of foreign-born individuals in the United States reached nearly 40 million, or 13% of the national population, in 2010. Foreign-born workers represent a growing proportion of the U.S. workforce and have some of the highest worker fatality rates of any population. Census data estimates show that a large number of foreign-born individuals have limited English proficiency (LEP). and limited education, inhibiting their ability to understand safety and health training and other rights on the job. This lack of understanding places LEP workers at increased risk of workplace injuries and fatalities. Occupational safety and health training is fundamental for the safety of workers and is required under many regulations. Employers must ensure that their employees are safe by taking measures such as providing training and placing engineering controls in workplaces. It is important that employers customize training programs to their specific worker populations so as to ensure that information is understood and acted on. Research has shown that workers are safer and training is more effective when workers receive training in a language they understand. Thus, it is critical that safety and health training be provided in a language and at a literacy level that workers understand. This applies to both training delivered in person and computer-based training.
Relationship to Existing APHA Policy Statements
- APHA Policy Statement 7715: Informing Workers of Occupational Health Risks
- APHA Policy Statement 8102: Occupational Health and Safety Services for Minority Workers
- APHA Policy Statement 8416(PP): Increasing Worker and Community Awareness of Toxic Hazards in the Workplace
- APHA Policy Statement 8714: Strengthening Worker Community Right-to-Know
- APHA Policy Number 201110: Ending Agricultural Exceptionalism: Strengthening Worker Protection in Agriculture Through Regulation, Enforcement, Training, and Improved Worksite Health and Safety
The demographics of the United States workforce have changed significantly over recent years, catalyzing the need for employers to modify their occupational safety and health (OSH) training. Safety and health training is an instrumental component of a comprehensive hazard control program, in addition to implementing a hierarchy of controls and upholding management responsibility. As workplaces and workforces continue to change, the effectiveness of OSH training is critical to ensuring safe workers and workplaces. As the proportion of foreign-born workers and workers of limited English proficiency (LEP) continues to increase, so does the need to expand training in order to comply with both existing and emerging labor requirements. The demand for training in a language workers understand is generating a shift in approach for employers, union trainers, community health promoters, and educators. Responding to increasing ethnic diversity appropriately is crucial for both the public and private sectors.
The Bureau of Labor Statistics (BLS) publishes reports on work-related injuries and fatalities annually. These reports help highlight the dangers faced by immigrant and, often, LEP workers. In 2015, more than 943 immigrant workers were killed on the job . Data on Latino or Hispanic workers, among the most commonly reported data by the BLS, help provide details on risks to immigrant workers. In 2014, there were 19.3 million Latino immigrants living in the United States, representing 35% of the country’s Latino population. In 2015, 903 Latino workers died on the job, the highest number since 2007. The fatality rate among Latino workers was 4.0 per 100,000 workers, whereas the nationwide fatality rate was 3.4 deaths per 100,000 workers. The Latino fatality rate was 18% higher than the national average, and 67% of Latino deaths were among immigrant workers.[2,5] According to BLS data, the Hispanic/Latino worker fatality rate has been consistently higher than the national fatality rate since 1995. According to estimates, the Hispanic/Latino population will account for nearly 20% of worksite fatalities by 2050.
Understanding the characteristics (e.g., country of origin, gender, age, citizenship, employment status, work sector) related to the highest numbers of immigrant and LEP fatalities may help identify areas of greatest need and may inform immediate actions. In 2015, foreign-born workers who died had origins in about 100 different countries.[2,5] Workers from Mexico accounted for a majority of those fatalities (415), while workers from El Salvador, Guatemala, and India accounted for 42, 36, and 35 deaths, respectively.[2,5]
Immigrants work in some of the most dangerous industries. Construction was the industry responsible for the largest number of fatalities among foreign-born workers in 2015, accounting for 275 deaths [2,5]. Additional high-hazard industries include agriculture, forestry, fishing, and hunting (22.8 deaths per 100,000 workers); mining (11.4); and transportation and warehousing (13.8).[2,5] Commercial fishing is one of the most dangerous industries in the United States, with nearly 112 deaths per 100,000 workers. According to one study, Vietnamese fishermen are estimated to make up more than 50% of the commercial fishing industry in the Gulf of Mexico, particularly the shrimp industry, and they are at a particularly high risk of injury. More than half of those surveyed in that study reported speaking no or little English and, despite working in an extremely dangerous industry, considered their job “safe.” Data have shown that LEP and immigrant worker communities, as a result of working in these industries, have disproportionally high injury and fatality rates.
In 2017, Liberty Mutual Insurance issued the Workplace Safety Index, which estimated the cost of disabling work-related injuries for employers at $60 billion per year, or more than $1 billion per week. However, this figure has been identified as a serious underestimate, with the total costs of occupational injuries and fatalities estimated at $250 billion to $370 billion a year. In the end, workers and their families face an economic burden that is astronomically higher than some resources have identified. The economic burden of work injuries is similar to that of cancer and greater than that of diabetes or stroke.
These vulnerable worker populations require additional resources and efforts to reduce this disparity through bridging the knowledge gap via effective safety training. Educating workers about the known risks and hazards at their workplace in a manner they can comprehend and understand can empower them in avoiding injury and illness. It is important to note that safety and health training that is culturally relevant and that is conducted at an appropriate literacy level and in an appropriate language is a critical element of a safe workplace for all workers, including others at risk such as LGBTQ workers, those who may be homeless, and members of racial minority groups.
The Occupational Safety and Health Act (OSH Act) was passed in 1970. This legislation required employers to provide safe and healthful work environments to prevent workers from being injured or killed. Part of the OSH Act was the mandate that workers have the right to receive information and training about hazards and methods to prevent harm. Decades later, in a 2010 training standards policy statement, the Occupational Safety and Health Administration (OSHA) reiterated and clarified employers’ obligation to present safety and health training in a form that employees understand. Employers are required to instruct their employees using both a language and a vocabulary that workers can comprehend. The policy statement was designed to clarify OSHA’s original intention for training and instruction. Previously, some employers had misconstrued the training language described in a given standard and did not understand the intent that workers must understand what they are being taught. The courts and the Occupational Safety and Health Review Commission have agreed with OSHA that employers cannot take advantage of “an adequately communicated work rule” when the rule has not been communicated in a language employees can understand.
Numerous OSHA standards, such as the Lockout/Tagout Standard and the Bloodborne Pathogen Standard, contain specific requirements for employee training comprehension. The Lockout/Tagout Standard states that employers must verify that employees have “acquired” the knowledge and skills they were taught. The Bloodborne Pathogen Standard states that employers are required to provide “an opportunity for interactive questions and answers with the person conducting the training session.” Workers’ comprehension is a basic component of many safety and health standards. However, comprehension is not specifically mentioned in the training section of other standards. The OSHA policy statement reiterates that, even when not specifically mentioned in a standard, worker training required by OSHA standards must be presented in a way that workers understand. Following the Gulf of Mexico oil spill in 2010, the National Institute for Occupational Safety and Health (NIOSH) reiterated these requirements and mandated that training for cleanup workers be conducted “in a manner and language that workers understood.”. Training was therefore provided in English, Spanish, and Vietnamese.
In addition, the U.S. Environmental Protection Agency (EPA) Worker Protection Standard, revised in 2015, requires employers to ensure that agricultural workers receive OSH training in a language and vocabulary they understand. However, potential challenges remain with the implementation of the standard, as the resource materials and training provided are currently in English and Spanish and do not address other languages spoken among agricultural workers (including indigenous languages).
Training is defined as planned efforts to facilitate the learning of specific competencies. The collection of competencies needed for success in a specific environment includes knowledge, skills, and behaviors. Previously, the majority of OSH training in the United States, both knowledge and skills based, was provided by employers and organized by union representatives or Coalition on Occupational Safety and Health groups. The influx of 40 million foreign-born people in the United States requires a systematic change in training. A new form of OSH training has emerged to address changing needs in the workforce. Community-based organizations have created OSH training programs that specifically target non-union workers, who were previously left out. The aim of these organizations is to unify members of the target group and program developers in order to “establish trust, share power, foster co-learning, enhance strengths and resources, build capacity and examine and address community needs and health problems.” In many instances, community-based organizations focus on workers of a particular language or ethnic background or workers from a specific industry sector or geographic location. Immigrants and LEP learners often prefer community-based organizations because they can communicate in the same language and incorporate cultural beliefs into training.
Workers who have limited English-speaking ability or low levels of literacy need to be considered in the development and presentation of material. Trainers should avoid using word-dense materials and select materials with a large number of visuals, simple language, practical examples, and bullet points. Program developers must be cautious with direct translations of English text into a worker’s language given their risk of failure. To achieve complete understanding, translations of English content need to reflect workers’ dialects. Translations of slang, acronyms, and technical terms may need to be customized for each language and target population to ensure not only a literal translation but a translation of the intent and actual meaning of a term, gesture, or image.
While it is important to consider the needs of LEP workers, it is a mistake to assume that simply because workers are not proficient in English they also have low literacy in their native language. Many immigrants and refugees come to the United States with special training, academic degrees, and certifications from their country of origin. For this specific worker population, training in their native language does not preclude training in advanced, technical subjects. Understanding the native literacy and educational levels of trainees is important in creating effective training materials.
Incorporating social and cultural practices and using a language workers understand have been shown to facilitate more effective OSH training. Vietnamese workers who received safety training after the Gulf oil spill in a language other than Vietnamese rated the training as less effective, often citing difficulties with poor translation and a lack of culturally relevant examples. These same workers later reported fewer safety behaviors than individuals who received training in their native language, along with lower levels of engagement in practices to reduce risks, less frequent safe removal of personal protective equipment, and less frequent use of reference materials regarding employee rights and safety. Similar results were found by a team studying Vietnamese fishermen, who noted that fishermen provided with culturally appropriate, language-specific (Vietnamese) safety training and images reported increased “intent to action” and had higher attitude scores.
A recent study revealed that Latin American women preferred health communications illustrated in a fotonovela, a specific form of illustration in which a story is told through a series of photos with dramatic captions similar to those they normally see in Spanish soap operas. Similarly, another study showed that a Spanish fotonovela educational play and pamphlets effectively promoted safe lifting behaviors among Latina workers in fruit warehouse shops. Another study identified the importance of understanding cultural values and beliefs that can affect worker behaviors. An important role for a safety and health trainer is to clarify cultural myths. Many Latin Americans believe that showering after working under the hot sun may cause rheumatism. This cultural belief prevents workers from removing dust and prolongs their exposure to skin toxins. Another cultural concept often included in effective training is familism. Familism is a strong attachment to the nuclear and extended family. It has a deep-rooted value among many immigrant communities, and incorporation of familism into training content and materials can increase workers’ compliance with safety and health policies or procedures by illustrating the family-related health consequences of not doing so.
A study conducted by the Center to Protect Workers’ Rights and OSHA highlighted the need for training in a worker’s language. Spanish-speaking construction workers shared their reality of safety and health training, expressing that they did not understand safety procedures when they were explained. According to one worker, often “the foreman gets frustrated and just tells them to skip that part because they don’t understand. They just do it without safety equipment or procedures.” Another interviewee, a 60-year-old Cuban-born electrician with 23 years of experience in the United States, said, “Training in our own language is very important. When I don’t understand, I can always ask for help. We will get more benefit, and we will prevent more accidents…. It is easier for me because of my years of experience to associate my work with the training and understand. But what about those that are new in the construction work? It is impossible for them to understand training in English and know the difference.” This study provides vital information on workers’ experiences when employers are noncompliant with safety and health training policies required by law and demonstrates that individuals who work in high-hazard industries such as construction have a higher risk of injuries.
Some employers may be challenged by limited institutional knowledge of how to work with immigrants and the lack of a bilingual infrastructure. Searching for effective methods to improve safety training for immigrant workers is a fundamental step toward reducing occupational disparities. In response to this need, OSHA created a web-based tool to facilitate employers’ safety and health training and to better assist employers with LEP workforces. Resources, including information customized for LEP populations in specific industries, are available in Arabic, Chinese, Haitian Creole, Korean, Nepali, Polish, Portuguese, Russian, Spanish, Tagalong, Thai, and Vietnamese. In addition, OSHA provides foreign-language safety and health resources developed through the Susan Hardwood Training Grants program. This program, which awards grants to nonprofit organizations to improve the safety and health of vulnerable populations, has reached and trained more than 2.1 million workers since 1978. Through grants awarded by the program, employers, union trainers, community health promoters, and educators have access to safety materials in various languages such as Chinese, Spanish, and Vietnamese.
Language justice is imperative not only for the well-being of workers but also for the economic prosperity of the United States. Language justice in training can increase worker safety and, therefore, reduce injuries and fatalities, decrease workers’ compensation claims, and increase worker productivity and morale.
Evidence-Based Strategies to Address the Problem
Safety training evaluations in multiple industries have shown that training conducted in a worker’s native language is more effective and that training led by peers or those with similar cultural understandings helps improve workplace safety. In addition, adult learning approaches and the use of alternative teaching strategies (such as photos) help in effectively communicating safety information, regardless of workers’ reading levels or language barriers. NIOSH has identified knowledge, cultural, and structural barriers as three types of obstacles to OSH training among LEP workers. Frequently, immigrant workers are unfamiliar with materials, technology, and safety procedures and regulations and may perceive risks differently. To improve the effectiveness of OSH training, NIOSH recommends simple, common language and the use of large pictures. The content of training sessions should include information about how to recognize and avoid hazards, the impact of hazards, and how to address problems at work.
Studies in multiple industries have shown the use of these adult learning and LEP approaches to be effective in improving safety training. The use of images to improve understanding is part of the OSHA Hazard Communication Standard and is supported by more than 20 years of research, including studies involving LEP populations.[23–25] Additional research and publications note that the use of hands-on activities, images, and peers facilitates adult and LEP training.[20,21] Research in Iowa showed that meat industry employees’ knowledge and behaviors improved when training was conducted in native languages and effectively communicated to Spanish-speaking trainees who had less formal education than their English-speaking counterparts. In addition, training of Vietnamese fishermen in Vietnamese was found to “favorably increase attitudes, use and behavior intent” regarding major risk factors.
In 2006 the U.S. Department of Labor, through its Employment and Training Administration, started an initiative that awarded $4.9 million to organizations in California, Minnesota, Nebraska, New York, and Texas to test innovative techniques for delivering language and employment services to LEP and Hispanic workers. This initiative represents an early step in the delivery of vocational training to individuals in these populations. Upon conclusion of the grants, the final report showed that successful LEP and Hispanic workforce programs included active engagement by employers to adapt a curriculum tailored to meet specific workplace requirements and provision of incentives for completion of the curriculum. While the program did not specifically address safety and health training, the report highlighted the fact that the English skills gained by participants improved both their chances of finding and retaining employment and their ability to interact with coworkers and members of their communities.
An additional study highlighted how Latino immigrant workers’ behaviors reflect a culture that places a high value on hard work. The study findings showed that these workers display overt demonstrations of their productivity to please employers and to create a reputation as good employees. While this effect gives them a competitive edge in the labor market in terms of securing employment, over time it can lead to an increased risk of injury. Immigrant workers also face economic insecurity, deportation, and discrimination. Training therefore must address not only linguistic and educationally appropriate information but cultural norms, traditions, and perceptions. Peer trainers or those from a similar culture who may already work in a similar role can be critical figures in helping address and explain cultural differences and norms in addition to critical safety procedures.
NIOSH commenced a partnership with the Mexican Consulate in El Paso, Texas, and its local partners to disseminate training materials. NIOSH aggregated curricula to train promotoras (community health promoters) to integrate OSH-related subjects into their work and networks. The program is currently being piloted and finalized. The promotora model is well known and effective in connecting with hard-to-reach communities. Expanding this program with consulates of different countries nationwide can spread language justice. In addition, NIOSH and OSHA have worked with nongovernmental organizations to disseminate language-specific and LEP resources to increase awareness of workplace exposures and hazards as a means of improving worker safety.
Moving to language justice in training: Employers have a duty to provide a safe workplace, including training workers in a language they understand. This concept of language justice, for all workers regardless of language, is an important step in providing safe workplaces to protect workers in dynamic, changing work environments.
Ensuring that workers who speak languages other than English understand the safety and health training they receive is time consuming and expensive. In workplace surveys, employers often cite the amount of time required for LEP training as a reason for not conducting training. Solutions to this challenge include offering training for LEP workers at the same time as for English-speaking workers. This eliminates the potential for English-speaking workers to feel that LEP workers receive “special treatment” and ensures that all employees are trained and ready to work at the same time. OSHA mandates that workers be provided safety training in a language they understand, and thus training is required regardless of the time it takes. It is also more economical than occurrences of injuries and fatalities.
In a workplace with workers from multiple countries who speak a variety of languages, translation of materials into several languages may present a challenge if there are not trainers familiar with all needed languages and cultures. Peer training, even from peers who are not formal trainers but who may be bilingual, has been shown to effectively communicate health and safety matters. With the increase in community training organizations, employers in need of specific language services may be able to reach out to the worker community of trainers for bilingual support. A well-designed training program should also include a large number of images and diagrams, which will reduce the number of documents needing translation. Research has shown that “merely translating material into another language does not ensure that workers will completely understand potential hazards in the workplace,” thus proving that simply printing materials in another language while conducting training in English is not sufficient. Translation of documents alone is a skill different from interpretation (speaking in the given language during training), and neither alone is sufficient for understanding. A number of networks of community language translators and interpreters have been established and may be a valuable resource for those seeking translation and interpretation. Therefore, peer or community trainers can support employers’ efforts to provide training in a language that is understood but is also culturally similar to that of workers.
One common argument for not providing training in a language other than English is that if employees do not understand training in English, they will not be able to understand English signs in the workplace and may not be sufficiently literate for their position. Research has shown that English fluency is not necessarily an indicator of workers’ literacy level in their native language. Many workers, once properly taught, are able to perform skilled work. An important element of training for LEP workers is to teach recognition of English-only signs. The cost of not including this training component may include extensive injuries to workers and damage to facilities.
All of the above activities (training, translation, etc.) come with a cost. Employers often cite cost as a major barrier to offering training; however, providing safety training reduces insurance costs and eliminates or reduces fines, litigation costs, and workers’ compensation claims. Costs are also saved when a trained worker can stay on the job, reducing the overhead of onboarding new trainees to fill the role of an existing but injured worker.
APHA recommends that the following steps be taken to achieve language justice in occupational safety and health training:
- OSHA should strengthen outreach on its 2010 training standards policy statement. During inspections, OSHA should continue to assess whether safety training is conducted in a language and at a literacy level that workers understand.
- NIOSH should conduct further research to identify additional questions regarding the nature, extent, and effectiveness of training in immigrant workers’ native language.
- BLS reports and/or surveys should include language or country of origin in additional details (e.g., beyond “Hispanic”) to help better identify at-risk workers and their native languages.
- OSHA should promulgate a national training standard to address the ways in which training should be provided (based on proven methodologies for adult learning requiring employers to verify that workers have acquired the knowledge and skills in which they have been trained).
- The EPA should ensure funding for materials to address the distinct languages and cultures within the agricultural workforce and strongly encourage that these materials be developed with ample worker involvement.
- Infuse the concept of language justice into discussions of health and safety training.
- Incorporate into training practices that encourage active participation by learners.
- Centralize access to resources on training and language justice, particularly through Internet-based platforms.
- Improve communication between training staff and community partners.
- Develop and disseminate a training curriculum for community, union, or worker interpreters on interpretation methods and ethics
- Develop a national database of language groups and their geographic and industry sector distributions throughout the United States.
- Develop a national pipeline of qualified translators and interpreters for the dozens of languages used by members of the U.S. workforce.
- Compile and distribute best practices for interpretation and translation of safety and health materials.
- Researchers and advocates should continue to identify best practices and cost savings afforded by worker safety training to further strengthen evidence that regulatory mandates for training are feasible and cost effective.
- Employers should develop hazard assessments and work plans to identify barriers to safety that may stem from language and literacy issues and take action to address these barriers as a means of ensuring that training is effective.
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