Is your operation ready for an Occupational Safety and Health Administration inspection? If not, it’s time to get prepared. It’s important to understand why OSHA is conducting safety inspections, then know how to be ready for one at any time.
“Our industry has consolidated and we employ an increasing number of non-family members,” says Leonard Meador, management consultant, Rossville, Ind. “It opens you up to different scrutiny.”
For instance, a disgruntled employee could turn you in for both minor and major safety issues. Also, other state and federal agencies can refer your operation to OSHA, as can individual citizens. “More people can come to a farm today, look around and determine things should be investigated,” says Meador.
Another reason is that insurance companies are taking more interest in an operation’s environmental and safety procedures. They want to know how you set up and follow these policies and procedures.
“OSHA inspections haven’t been on the forefront because the U.S. Department of Labor hasn’t given agriculture a real high priority,” says Meador.
The Labor Department issues Standard Industrial Certification codes for particular farm types, such as pork (0213), dairy (0241) and general agriculture (0219). The agency keeps track of how often those sites have an incident. As the incident pool grows for an SIC code, the department steps up inspections.
“In the past, pork operations haven’t been large enough to generate many incidences,” adds Meador. “But now, one owner may have 15 production sites across the country.”
A random inspection is unlikely, but it takes only one employee to raise the profile. Activist groups also know this can be a way to hinder your operation.
OSHA does have a database of employers in each state and randomly picks businesses to inspect.
“Government entities are working together more often,” says Gary Walters, director of processing safety and risk management, Premium Standard Farms. “That seems to occur more often in state-run OSHA offices. North Carolina and Iowa are two of 13 states that are state-regulated, but have to meet or exceed federal guidelines.”
“I look upon OSHA as a resource, not an opponent,” adds Mike Brown, director, safety and animal welfare, PSF-North Carolina. “OSHA inspectors go to regional meetings and make themselves available to us.”
PSF has had some OSHA inspections and has done well. “You have to prove yourself to these people,” notes Brown. “They’re there to assist and regulate. OSHA officials do look at incident rates and employee lost time. High levels throw up red flags.”
Along with OSHA, there are many resource people within each state who are willing to help you become OSHA compliant. For example, in North Carolina these include agricultural Extension, university personnel, the state’s Department of Labor and individual consultants.
Now that you know why OSHA is looking more closely at agriculture, here are a few pointers on how to be prepared for an OSHA inspection.
For starters, the best thing to do is to develop a safety manual, train your employees and conduct regular safety meetings. It’s also wise to have an independent inspector, who’s familiar with OSHA, conduct an on-site safety review.
Brown agrees. PSF requires that its production employees attend regular safety meetings. “It’s not an hour-long, drawn out class,” says Brown. “They’re done in about 10 to 20 minutes. This allows me to focus on safety, and then employees can return to their jobs.”
In addition, PSF has a safety manual that’s updated regularly. This is where Brown draws some of his materials for monthly safety training. He also uses OSHA and the North Carolina Department of Labor’s audiovisual library for safety information.
“Look at safety as a natural part of the business,” says Walters. “If you look at the OSHA 1910 general industry guidelines on the agency’s Web site (www.osha.gov), the agricultural section focuses on procedures to develop an intricate safety program.”
Another feature on OSHA’s Web site is a section of generic e-tools to establish programs that you can adapt to your own worksite. One example involves the steps to conduct an effective risk assessment of your operation.
The risk assessment helps with regulatory compliance and establishing safe work practices. It can provide the necessary basic information to make improvements that ensure a safer workplace and save money.
The Web site also helps you assess other safety areas within the work environment such as electrical wiring, proper employee recordkeeping, training procedures, job-hazard analysis and respiratory protection ideas.
The respiratory section defines regulations and training procedures to protect pulmonary functions, including tips for working in confined spaces. Other things that you should consider providing include cardiac-pulmonary recitation and first-aid training.
Brown notes that 66 percent of PSF’s North Carolina production workforce is Hispanic. “We make sure that all safety materials are translated into English and Spanish, including personal-protective equipment and workplace assessments,” he says. He also uses the resources of bilingual employees at every production location.
Besides the monthly meetings, Brown feels strongly about continuous safety checks and balances. He conducts safety inspections at every site at least twice a year. Most are unannounced. This is to provide a realistic assessment of the procedures and challenges.
“Everyone is held accountable,” says Brown. “Keep the focus on a proactive approach; not a reactive one.”
He notes that it’s important to have everyone’s buy in to the program, including upper and senior management.
This past fiscal year, PSF’s North Carolina production operations didn’t have a lost-time incident on any farm site and few reportable incidents. Company officials held an event to commend employees and celebrate 1 million man-hours without lost time.
“No one has ever had 1 million hours of no lost time in pork production,” Brown cites from North Carolina’s Department of Agriculture statistics.
A lot of PSF’s success comes from creating a team and making employees part of the effort.
“All of those pieces create an effective safety program, help maintain your workforce in a safe environment and ultimately reduce workers compensation claims,” says Brown.
There is an increased chance that OSHA will pay you a visit in today’s industry compared to just five years ago. You should already have a safety program in place for your system, if not, it’s time to get started.
Safety Follow Up
When you conduct follow-up safety inspections on your farm, employee training is important but there are other criteria to consider. Here are some tips from Mike Brown, safety manager/animal-welfare coordinator, PSF-North Carolina:
1. Make sure that management fully supports the program, the time and attention that it will involve. Point out the benefits the operation will gain.
2. Take training protocols to the employees’ location, in person or via video. Don’t make employees come to you.
3. Reinforce safety training with regular on-site inspections; get employees involved. Make it educational, not criticizing.
4. Have protocols in place on how to proceed if OSHA does visit your operation.
For more information
For more ideas on how to get your operation OSHA compliant as well as for safety resources, go to OSHA’s Web site at www.osha.gov. Click on agriculture operations in the alphabetized index.