OSHA Inspections: The Dairy Dozen

If you are a dairy farmer, chances are that you have already heard about the new OSHA regulations and the inspections expected to take place on New York State dairy farms starting sometime in 2014. (If not, refer to ?What to Expect from OSHA Inspections? in the September 2013 issue of Ag Focus). Here are the basics: only farms that have employed more than 10 employees in the past 12 months (excluding immediate family members and including part time employees) or have a temporary labor camp are required to comply with OSHA regulations.

On September 27th, Farm Credit East hosted the second webinar in a series about OSHA regulations and inspections. (To view the webinar, visit the following web address: https://www.farmcrediteast.com/en/Webinars/2013SeptOSHA.aspx). Ron Williams, the Compliance Assistance Specialist for the Department of Labor-OSHA in the Syracuse office, laid out the basics for OSHA inspections of dairy farms. A Compliance Safety and Health Officer (CSHO) will arrive unannounced on the dairy to complete the inspection. The CSHO will present their credentials, conduct an opening conference, review records and programs, complete a walk around of the farm, and then hold a closing conference. Any violations will be discussed during the closing conference, and farms will have 15 days to accept and pay citations or to appeal.

Here are the ?Dairy Dozen?, the top twelve areas that will be reviewed by OSHA during dairy farm inspections:

1. Manure storage and collection structures
2. Dairy bull and cow behavior/worker positioning
3. Electrical systems
4. Skid steer operation
5. Tractor operation
6. Guarding of PTOs
7. Machine guarding on field and farmstead equipment
8. Lockout- Unexpected energy release
9. Hazard Communication
10. Confined spaces
11. Horizontal bunker silos
12. Noise

Do you see any areas in which your dairy could improve safety or safety training? Dairy farm employers are required to train employees on new labeling elements and the new Safety Data Sheet (SDS) format by December 1st, 2013 (that?s right, you have less than a month!), so Hazard Communication training this is a good place to start. Remember that it is very important to keep records of any trainings conducted for employees because according to Ron, ?If you didn?t document it, you didn?t do it?. Visit https://www.osha.gov/dsg/hazcom/index.html for training guidelines and resources. You can also contact Libby Gaige at geg24@cornell.edu or 607-793-4847 for more information.