On September 3, 1991, an industrial fire caused by a failed improvised repair to a hydraulic line destroyed the Imperial Food Products chicken processing plant in Hamlet, North Carolina, United States. Despite three previous fires in 11 years of operation, the plant had never received a safety inspection. The fire killed 25 people and injured 54, many of whom were unable to escape due to locked exits. It was the second deadliest industrial disaster in North Carolina's history.

Imperial Food Products was a corporation owned by Emmett Roe, who acquired the Hamlet facility in 1980 to produce chicken products. The company had a poor safety record at one of its other plants, and the Hamlet building lacked a fire alarm or an operational fire sprinkler system. For reasons that remain disputed, Roe ordered several exterior doors of the plant locked in the summer of 1991—including a labeled fire exit—in violation of federal safety regulations and without notifying most workers. In September, the plant's maintenance workers attempted to replace a leaking hydraulic line, attached to the conveyor belt which fed chicken tenders into a fryer in the processing room, with improvised parts. On September 3 at around 8:15 am, they turned on the conveyor belt after altering the line; it separated from its connection and spewed hydraulic fluid around the room. The fluid vaporized and was ignited by the fryer's flame. Fire engulfed the facility in minutes, severing telephone lines and filling the plant with hydrocarbon-charged smoke and carbon monoxide.

There were 90 workers in the plant at the time. Some were able to escape through the plant's front door, while others could not leave due to locked or obstructed exits. Brad Roe (Emmett's son and the company's operations manager) drove to the local fire station for help since the telephone line had burned; firefighters reached the scene at 8:27 am and sent a mutual aid call to other fire departments. Over 100 medical and emergency service personnel ultimately responded. A delivery truck at the loading dock and a dumpster were moved to create openings. One maintenance worker kicked through a locked door to free himself and some of his coworkers. Firefighters brought the fire under control by 10:00 a.m. Most of the dead were killed by smoke inhalation. Of those who died, 18 were female and 7 were male; one was a vending machine deliveryman and the rest were Imperial workers.

The plant permanently closed and Imperial Food Products, fined a record-high state-imposed $808,150 penalty () for safety violations, declared bankruptcy. Survivors suffered long-term adverse health effects, including respiratory ailments, muscular injuries, and cognitive impairments. Roe pled guilty to 25 counts of involuntary manslaughter and received a 20-year prison sentence, of which he served about four years. The North Carolina General Assembly passed 14 new worker safety laws, including whistleblower protections, and the state inspector corps was increased from 60 to 114 personnel.

Background Imperial Food Products plant in Hamlet Emmett J. Roe founded Imperial Food Products Incorporated (commonly called Imperial) in Moosic, Pennsylvania in the 1970s after acquiring a food processing plant from his former employer, Empire Frozen Foods. The corporation supplied grocery stores and distributors with chicken products. Roe purchased the largely-decommissioned Mello-Buttercup Ice Cream plant, located along Bridges Street in Hamlet, North Carolina, in September 1980. The location was chosen for its proximity to poultry suppliers and markets, and for North Carolina's lower labor costs relative to the rest of the United States. The facility was situated in a predominantly African American area of Hamlet. A one-story building of bricks and metalwork, the plant's basic structure dated back to the early 20th century. The building was extensively renovated before becoming operational and expanded from to . Seven of the changes that were made to the building required permits by law, but Roe never applied for them. Roe's son Brad became the leader at the new plant as operations manager several years after it opened; another family member, James Neal Hair, worked as his deputy as plant manager. The Roes recruited a workforce dominated by impoverished and undereducated people, including many single mothers and high school dropouts. The plant produced a variety of custom chicken products from pre-cut frozen chicken breasts, but mostly made battered deep-fried chicken tenders which were sold to restaurants in the American South, including regional locations for Long John Silver's, Red Lobster, Captain D's, and Shoney's.

North Carolina law required new industrial businesses to apply for a license to operate, and any business with 11 or more employees to register with the North Carolina Department of Labor and the United States Occupational Safety and Health Administration (OSHA). Although OSHA was a federal agency, North Carolina had assumed responsibility for enforcing its safety standards in the mid-1970s. Registering a business with the Department of Labor would add the workplace to a lottery for a surprise inspection. Roe never applied for a business license and did not register the plant with the labor department. Roe also did not register the plant with city or Richmond County taxation authorities and never paid any local property tax, despite being asked by officials to do so; Imperial Food Products ultimately owed local governments thousands of dollars for unpaid taxes and water and sewage bills by September 1991. Hamlet was economically depressed and local officials, valuing the employment it gave to residents, chose to treat Imperial with "benign neglect", according to city manager Ron Niland. By 1990 the company was one of the largest private employers in Hamlet. Niland got into a dispute with Imperial that year after it was found to be dumping excess chicken grease into the municipal wastewater system. He threatened to close the plant, but dropped the matter after the company changed its wastewater disposal methods.

Roe acquired three additional meat processing plants in the late 1980s, taking on significant debt in the process. By 1990, the facility in Colorado had lost its largest customer and was operating below capacity, the facility in Cumming, Georgia had been damaged by two fires, and the plant in Alabama was forced to close after its contracted food broker rejected the low-quality nuggets it produced. Under pressure to recoup his losses and pay back his creditors, Roe devoted his attention to the Hamlet plant. He and Brad added a full second shift to increase production and sped up the line process. When repairs to equipment were necessary, Brad typically instructed the maintenance crew to improvise with spare parts to save money.

Safety concerns The Hamlet plant experienced small fires in 1980, 1983, and 1987, but none resulted in safety inspections. One of these fires disabled the fire sprinkler system installed by Mello-Buttercup; it was never repaired. An automatic carbon dioxide fire extinguisher and hood were installed over the deep fryer vats after the 1983 incident. A state OSHA inspector visited the site several times in the 1980s to examine the small facility space leased to the plant's former owner, Mello-Buttercup, but did not visit any of Imperial's sections; the Imperial facility never underwent a workplace safety inspection.

Line workers were only given partial safety guidelines in their hiring orientation, which did not cover fire safety. The only managerial staffer possessing a state-issued OSHA safety booklet found its content confusing. One worker wrote a complaint to OSHA in October 1987 alleging the presence of maggots in the breakroom and lice and detritus in the women's restroom. Questioned by an OSHA officer, Hair denied these claims and no further action was taken. In 1991 the North Carolina General Assembly passed a law requiring all local governments to appoint a fire inspector by July 1 to examine all commercial buildings within their respective jurisdictions to ensure compliance with the new state fire code. The statute did not appropriate money for the purpose and many municipalities, including Hamlet, lacked the funds to appoint such an official. The Hamlet Fire Department also had no contingency firefighting plan for the Imperial plant.

Food safety inspectors from the United States Department of Agriculture (USDA) visited the plant daily to examine the quality of the chicken, check for insects and vermin, and ensure that the facility's workers and processes were hygienic. In 1989, the inspectors noticed a large number of flies entering the building near its loading dock and dumpster. To resolve this issue, in the summer of 1991 Imperial built a shed-like structure around the dumpster and trash compactor, without a permit. It had an interior door that opened from the plant to the dumpster and an exterior door that was to be locked from the outside at all times. The USDA approved the measure although the locked door violated workplace safety standards. One production line worker told a USDA inspector he had concerns about the facility's safety, but the inspector said that such issues were outside his purview. The maintenance worker who padlocked the door said Emmett Roe told him it was to keep workers from stealing chicken. While such thefts had occurred at the plant, this factor was later downplayed by other supervisors.

Other exits at the facility, including the breakroom exterior door, were also locked; of the plant's nine exterior doors, seven were locked or obstructed from the outside, including a padlocked one marked "Fire Exit Do Not Block". Only a handful of Imperial employees, mostly maintenance workers, were aware that the doors were locked. One maintenance worker stated that their request for a key to the locks was turned down. The plant did not have a fire evacuation plan, workers had never undergone a fire drill, and there was only one fire extinguisher near the fryer. There was also no fire alarm. One line worker suggested complaining about the lack of fire precautions to the managers, but her coworkers convinced her not to, saying it would jeopardize her employment. Most workers did not know that they could have complained to OSHA, or that the federal Occupational Health and Safety Act guaranteed protection from retaliatory firings for reporting safety concerns. The plant's lack of an emergency plan, lack of a fire alarm, and the locking and obstruction of doors all violated OSHA rules. State law also prohibited the locking of workplace doors.

Imperial experienced a string of safety issues with its Moosic plant in Pennsylvania in the 1980s. After a worker was severely burned by cooking oil in 1985, OSHA asked to inspect the plant. When Roe refused, the inspector obtained a search warrant and cited the corporation for several violations. Two years later, OSHA received an anonymous safety complaint, and upon further investigation found the Pennsylvania facility experienced twice the national rate of workplace injuries in food processing. An inspector again sought entry to the plant—which was refused—and obtained another search warrant. The inspector uncovered six violations and wrote in his report that Roe displayed "utter contempt for OSHA". A follow-up inspection recorded a total of 33 health and safety violations, including poorly marked and blocked emergency exits. Frustrated with the safety inspectors and a largely unionized workforce in Moosic, Roe closed the facility in 1989. The inspector noted the existence of the Hamlet plant on his report and suggested checking it, but nothing was done on this point. Because of Imperial's poor safety record, the company only obtained workers' compensation insurance in North Carolina from Liberty Mutual after being placed in the state's assigned risk pool.

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