A Safety Plan for Growers

By Chris E. Marsh, M.Ed.

Many growers are surprised to learn that they must follow Occupational Safety and Health Administration (OSHA) regulations. The section of the Code of Federal Regulations that pertains to agriculture is 29 CFR 1928. It is recommended that you look this up and become familiar with it, as it gives you direction as to what you are required to do in regard to safety from OSHA's viewpoint.

Growers need to develop safety plans for their operations. Since every farm uses different techniques, equipment, chemicals and policies, your safety plan should be unique to your farm and cover all reasonably possible hazards.
TRACTOR Photo © Deshaca m | Dreamst ime.com, SIGN © Treb999 | Dreamst ime.com.

If you have 10 or fewer employees, you do not have to keep OSHA injury and illness records unless OSHA or the U.S. Bureau of Labor Statistics informs you in writing that you must keep records under section 1904.41 or 1904.42. If you have more than 10 employees, you must keep records unless you are classified as a partially exempt industry under section 1904.2. However, if a worker dies, or three or more people are injured or ill from an incident and have to go away from the farm for further treatment, you must call OSHA and report the incident within eight hours no matter how many employees you have.

The OSHA law provides for two types of enforcement: A state can either be a "national" OSHA state for regulations and enforcement or have a "state plan" for regulations and enforcement. For state plans, the state enforces regulations. Their regulations have to be at least equal to the federal OSHA regulations. States may choose to have stronger regulations. You should determine which plan your state follows.

All power takeoff shafts, including rear, mid or side-mounted shafts, must be guarded either by a master shield or other protective guarding.
Photos by Chris E. Marsh unless otherwise noted

The purpose of this article is to give growers an idea of how to develop a safety plan for their operations. This is required of agricultural operations, and your farm should produce one. Each farm uses different techniques, equipment, chemicals and policies. Your safety plan should be unique to your farm and cover all reasonably possible hazards. Some of the things you may address could be covered by the General Industry portion of the regulations (29 CFR 1910). Any construction that you might do would be covered by the Construction portion of the regulations (29 CFR 1926). Since this article is not attempting to cover all types of farms and is a general report, you are responsible for finding out what is covered for farming in each section.

Developing the safety plan

Development of the safety plan is similar to planning to grow a specific farm product. There are several steps to take in growing crops, raising livestock or any other type of operation. The same holds true for the safety plan, except that you're dealing with your employees' health and safety.

First, you should sit down and list the different jobs there are on your farm. Next, list the things that could go wrong or are dangerous. Then you will need to determine what OSHA says about each item.

Second, using OSHA regulations, develop a plan for each type of standard that applies to farming, general industry or construction.

Third, you will need to develop a training session for employees on each topic that applies to your farm. For example, there are three standards listed in subpart C, section 1928. These are: rollover protective structures (1928.51), protective frames for wheel-type agricultural tractors (1928.52) and protective enclosures for wheel-type agricultural tractors (1928.53).

Subpart D covers safety for agricultural equipment. Section 1928.57 refers to guarding of farm field equipment, farmstead equipment and cotton gins. Under subpart I for general environmental controls, you'll find section 1928.110, covering field sanitation.

In addition to the above standards, there are seven specific standards in section 1910, General Industry, that apply to agricultural operations.

  1. 1910.142: Temporary labor camps
  2. 1910.111(a): Storing and handling of anhydrous ammonia
  3. 1910.266: Logging operations
  4. 1910.145(d)(10): Slow-moving vehicles
  5. 1910.1200: Hazard communication
  6. 1910.1027: Cadmium
  7. 1910.1201: Retention of Department of Transportation (DOT) markings, placards and labels

Five steps to a safety plan

Here you will find a suggested format for a safety plan and how to develop the content. There are five steps presented here, but it may take more or less for your farm.

  1. Read the section that applies to your agricultural operation.
  2. Pick out what exactly you do that is written about in the section.
  3. Have the different sections of the plan written.
  4. Determine how often training is required and make that part of the plan.
  5. Make a booklet for employees and have them sign for receiving the booklet. Then provide training as required on specifics of the booklet and standards. Do not try to shorten the booklet, because an OSHA inspector will not take "time" as an excuse for leaving out anything that applies.

The following is an example of the information and training that should be given to an employee before they operate a specific machine. It is given as an example and should not be the only form or information you use. It is abbreviated from the original standard (1928.57), which covers other issues regarding power equipment.

Farm field equipment

Power takeoff guarding

All power takeoff shafts, including rear, mid or side-mounted shafts, shall be guarded either by a master shield, as provided in the next paragraph, or by other protective guarding.

All tractors shall be equipped with an agricultural tractor master shield except where removal of the tractor master shield is permitted by the next paragraph. The master shield shall have sufficient strength to prevent permanent deformation of the shield when a 250-pound operator mounts or dismounts the tractor using the shield as a step.

Power takeoff-driven equipment shall be guarded to protect against employee contact with positively driven rotating members of the power drive system. Where power takeoff-driven equipment is of a design requiring removal of the tractor master shield, the equipment shall also include protection from that portion of the tractor power takeoff shaft that protrudes from the tractor.

Signs shall be placed at prominent locations on tractors and power takeoff-driven equipment specifying that power drive system safety shields must be kept in place.

Other power transmission components

Employers are required by OSHA to determine if personal protective equipment, such as helmets, should be used to protect workers.
The mesh or nip points of all power-driven gears, belts, chains, sheaves, pulleys, sprockets and idlers shall be guarded. All revolving shafts, including projections such as bolts, keys or set screws, shall be guarded, except smooth shaft ends protruding less than one-half the outside diameter of the shaft and its locking means. Ground-driven components shall be guarded in accordance with the previous two sentences of this section if any employee may be exposed to them while the drives are in motion.

Functional components

Functional components such as snapping or husking rolls, straw spreaders and choppers, cutter bars, flail rotors, rotary beaters, mixing augers, feed rolls, conveying augers, rotary tillers and similar units that must be exposed for proper function shall be guarded to the fullest extent that will not substantially interfere with normal functions of the component.

Access to moving parts

Guards, shields and access doors shall be in place when the equipment is in operation. Where removal of a guard or access door will expose an employee to any component that continues to rotate after the power is disengaged, the employer shall provide, in the immediate area, a readily visible or audible warning of rotation, as well as a safety sign warning the employee to look and listen for evidence of rotation and not to remove the guard or access door until all components have stopped.

Note that the first sentence of the above paragraph should be part of your training program. The operator should leave guards, shields and access doors in place while equipment is in operation. This is because the employee will be exposed to any component that continues to rotate until total shutdown.

A general industry requirement for agriculture

You must develop, implement and maintain a written hazard communication program at each workplace that describes how the criteria that are part of the standard for labels and other forms of warning, the Material Safety Data Sheets (MSDS), and employee information and training will be met. There must also be a list of the hazardous chemicals known to be present, using an identity that is referenced on the appropriate MSDS and can be cross-referenced with the files and containers. The employer must also describe the method to be used to inform employees of the hazards of nonroutine tasks and the hazards associated with the chemicals contained in unlabeled pipes in their work areas. Remember, all training must be done or provided in a language that each worker understands.

Many different chemicals are used in agriculture. What one farmer uses, the farmer next door may never buy, so if a new group of employees comes to work on your farm or orchard, they should receive this training. Do not depend on memory or hope that everyone knows what an MSDS is and how to read it.

Employers must obtain an MSDS for each hazardous chemical in the workplace and ensure that each sheet is available to the employees for immediate access during each work shift. You can obtain the MSDS from your chemical supplier or over the Internet. One thing that many people forget is that if you store diesel, gasoline or oil at your workplace, these are chemicals, have the potential to harm people or the environment through a spill, and require an MSDS. Immediate access would not mean a computer in a locked office. It would mean that, in the interest of employee safety and well-being, someone must be able to find information on the chemical dangers in just a few minutes.

Each container of a hazardous chemical must be labeled and marked with the identity of the chemical and appropriate hazard warnings. The label must not be removed, defaced or unreadable. If you transfer a hazardous material to another container, you must provide the same label as the original container, or a readable label that is large enough to let the worker know what is in the second container.

Employees must be trained at the time of their initial assignment and whenever a new physical hazard or health hazard is introduced into their work area. Training must include information on the hazardous chemicals present in their work area, protection against the hazardous effect of the chemicals, the requirements of the Hazard Communication Standard, the employer's hazard communication program, and the contents and use of MSDS. Training should be documented with the date of the training, the trainer's name and credentials, the name and social security number or work permit of each participating employee, and the subject of the training given.

The importance of MSDS

The main reason for an MSDS to be available is that chemicals have different ingredients. The combination of ingredients used to make the chemical can cause different reactions. Some chemicals are flammable, some are health hazards, some are corrosive, and some are reactive. There are also instructions to follow if you have a spill. The chemicals follow the DOT placards with the 1 to 4 numbering system to denote the level of danger.

Having this information available for other workers or for EMTs or other rescue personnel could mean the difference between life and death. If rescue personnel have to be called because of contact with a chemical, the most helpful thing that can be done upon their arrival is to give them a copy of the MSDS so they can determine immediately what type of treatment the injured or poisoned person should receive. This means they can start treatment immediately and also alert the ER to what is going on.

Where to get information

For more information on safety training, go to http://www.osha.gov and look up the topic you're interested in. In both General Industry and Construction, there are PowerPoint presentations and other OSHA training aids and information sheets that can be helpful.

Also, for any chemicals you may use, do not forget that your supplier should keep MSDS available to give to you. You should keep them in a notebook at several locations, depending on the size of your operation.

This article has attempted to give a brief explanation of what OSHA wants from businesses as far as following the safety standards they have initiated. Agriculture businesses are required by federal law (or state plan) to obey these standards if they apply. You need to remember that if you are inspected, you are being inspected by a person operating under federal law. There are procedures they must follow that you may read about, but if you refuse to let them enter, they may go to a U.S. attorney and get a search warrant for your operation. Also remember that if you have separate operations, they may, and often do, go to every operation you have, and they may bring help. l

Chris E. Marsh is an authorized OSHA trainer in both General Industry and Construction. He consults with many types of businesses and helps them with training, policy and other safety areas. He owns Ogeechee Training Service in Statesboro, Ga., and can be reached at ogeecheetrs@bulloch.net or 912-865-4500.