An Analysis of Preoccupancy Inspection Process

Every year tens of thousands of farmworkers arrive in North Carolina. The arrival of these migrant laborers is significant not just to North Carolina’s agricultural industry, but also to NC Department of Labor’s Agricultural Safety and Health Bureau (ASH).  

ASH’s mission is to administer workplace safety and health laws that apply to the agricultural industry.  This includes ensuring the health and safety of employer-provided migrant farmworkers’ housing. ASH strives to inspect and certify every migrant farmworker housing unit meets North Carolina’s migrant housing health and safety standards within weeks of being notified a grower plans to house workers. But, at times, the number of requests has exceeded the Bureau’s capacity to inspect each unit before the workers must start work. Late spring is an especially demanding time, as the influx of migrant farmworkers peaks. 

Rather than delay a grower’s ability to house workers, the agency offers provisional occupancy notices. Provisional occupancy notices can be issued after growers meet certain conditions, allowing workers to move in and begin work before ASH’s inspection is completed. 

“Provisional notices create a risk—for the workers, the growers, and the agency,” explained Jennifer Haigwood, Director of Communications & Policy Development for the Department of Labor. “For the sake of safety, we wanted to limit them.”

Once the Department of Labor’s leadership identified reducing provisional occupancy notices as a strategic objective for their agency, it launched a collaborative process improvement project with the Office of State Budget and Management (OSBM). to evaluate the migrant housing preoccupancy inspection process.

OSBM and agency partners in meeting
Department of Labor and OSBM partnered to conduct a process improvement analysis of the migrant housing inspection process

The Process

 The Department could have decided the way to reduce provisional notices was to request a budget increase to add more inspectors, but the easy answer is not always the correct or complete answer. Instead, the Department of Labor worked with OSBM to take a deeper dive into the process. 

OSBM organized meetings and facilitated in-depth discussions with stakeholders inside and outside the agency. They conducted interviews and site visits. They developed a detailed process map. Together, the project team identified issues surrounding each part of the process and possible root causes. 

The effort revealed inspection program challenges clusters in three areas:

  • A lack of staffing capacity
  • An outdated IT system
  • Inspection process inefficiencies 
image of a process map
A detailed process map was one of the earliest deliverables from the project.

“A project like the systems analysis we did with the Department of Labor is an opportunity to improve efficiency, effectiveness, and quality of services. We are just looking at how to better use state resources and better serve people,” said project lead and OSBM analyst Rachel Stallings.

One of the key elements of an improvement project like this is to bring everyone together to look at each step of the process and why it is done the way it is. A successful analysis engages everyone involved in the process, not just department leadership.

Engaging OSBM provided the Department of Labor with a neutral, outside perspective. OSBM could moderate discussions, ask questions, and see things differently because the analysts from OSBM were not part of the workflow. 

“The OSBM staff was so open and engaging. Their approach was so thoughtful. It was more than we could’ve asked for,” the Department of Labor’s Haigwood said of the project. 

The project team brainstormed potential solutions and improvements, evaluating each against key criteria and identifying feasible and realistic changes. Ultimately, the team identified nine solutions. The entire project took a year to complete.

The Path Ahead

Of the solutions identified by the project team, seven were short-term actions to improve efficiency, and two were longer-term changes that would result in significant improvements to the program. Immediate actions included improving training, enhancing the Gold Star Grower Program, and refining data collection and measurement. 

As an advocate for performance management, OSBM helps organizations identify successful outcomes and how to measure improvement on an ongoing basis. Encouraging performance metrics is part of all process improvement projects.  

“We encourage agencies to look at various metrics to evaluate what matters. In this case, the focus was on measuring the number of provisional notices, but we also looked at other relevant metrics like speed to complete occupancy certificates and formalizing a system for feedback,” explained Rachel. 

The onset of the COVID-19 pandemic disrupted some of the project’s action items. For several months in 2020, ASH couldn’t do in-person inspections and had to rely on provisional certificates.  However, the Department is thrilled to note that as of July, they have issued no provisional certificates in 2021.

“One of the best outcomes of this project was prompting an upgrade to the database our inspectors use,” explained Jennifer. “The old system bogged down the process and this project helped shine a light on what a difference this IT project would make.”

The Department of Labor’s Haigwood also explained the project helped the agency understand and document ASH’s capacity and process model. This makes it easier for the agency to build a business case for additional ASH positions, with a clear connection between resources and impact.  

Implementing improvements remains ongoing for the migrant farmworker housing certification process. But armed with a thoughtful analysis and a vetted roadmap, ASH is equipped to continue improving a process that is vital to the health and safety of migrant farmworkers.  

Nine Identified Solutions 

  1. Enhance the Gold Star Program annual training workshop
  2. Explore MOU with Department of Commerce for preoccupancy inspections
  3. Implement short-term data collection improvements to cut administrative time 
  4. Evaluate water bill collection and hot water process
  5. Simplify white card for growers
  6. Conduct biweekly teleconferences with staff
  7. Provide new and additional training for staff
  8. Add staff
  9. Upgrade ASH IT Data Collection System

About Migrant Farmworker Housing

DOL preoccupancy inspection of migrant housing at NC farm

The Migrant Housing Act of North Carolina (G.S. 95-222) governs standards for migrant worker housing and tasks the Department of Labor with inspecting all agricultural migrant housing to ensure compliance. A grower who owns or operates a housing unit for any number of migrant workers must register the housing with the Department of Labor at least 45 days before the workers’ arrival. The Department’s Agricultural Safety & Health Bureau manages the annual housing registration, inspection, and compliance program to ensure the safety and healthful condition of migrant farmworker housing.