Topics of Discussion

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1 Incorporating Worker Safety into Daily Farm Management Activities 2011 Dairy Summit December 7 8, 2011 Wisconsin Dells, WI Topics of Discussion Injuries, illnesses & fatalities on dairy farms Regulatory oversight OSHA Regulatory standards Inspections, citations & penalties Recordkeeping Safety management 1

2 Injuries, Illnesses & Fatalities on Dairy Farms 2

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4 Regulatory Oversight OSHA OSH Act & OSHA Until 1970, NO uniform and comprehensive provisions existed for work safety and their protection against hazards 4

5 Occupational Health & Safety Act of 1970 Passed by bipartisan Congress to assure so far as possible every man and woman in the Nation safe and healthful working conditions and to preserve our human resources. The Occupational and Safety and Health Administration (OSHA) was created within the Dept of Labor OSHA vs NIOSH 5

6 Applicability & Exemptions All employees and their employers under federal govt. authority are covered by OSHA Coverage is provided either directly by federal OSHA or through an OSHA approved state program OSHA does not cover the self employed or immediate members of farm families that do not employ outside workers Applicability & Exemptions A farmer who employs one or more persons has the legal responsibility to assure safe and healthful working conditions under the OSHAct. An amendment to the OSHAct prevents OSHA from spending any funds to issue or enforce any regulations that apply to any person who farms and employs 10 or fewer employees. 6

7 Applicability & Exemptions This amendment does not eliminate the possibility that an employee could use the regulations in a lawsuit against an employer. For this reason, all employers should comply with the act and provide their employees with a safe and healthful place to work. Applicability & Exemptions Amendment does not eliminate the requirement that an employer comply with the OSHAct, since the amendment does not eliminate rules or regulations. It only states that OSHA cannot spend funds to prescribe, issue, administer or enforce the agricultural regulations for employers of 10 or fewer people, except for those who have temporary labor camps. 7

8 Senator Feingold Letter July 10, 1997 from US DOL State vs Federal OSHA States must set job safety and health standards that are "at least as effective as" comparable federal standards. (Most States adopt standards identical to federal) States have the option to promulgate standards covering hazards not addressed by federal standards. AK, AZ, CA, CT, HI, IL, IN, IA, KY, MD, MI, MN, NE, NM, NJ, NY, NC, OR, PR, SC, TN, UT, VT, VI, VA, WA, WY 8

9 Regulatory Standards Standards As an employer, you have three general responsibilities regarding employee safety: 1) Comply with agricultural safety standards; 2) Comply with record keeping and other reporting responsibilities, (reporting accidents, posting of a citation, etc.); 3) Comply with the General Duty Clause 9

10 Employer Responsibilities Provide a safe and healthful workplace free of recognized hazards and follow OSHA standards Maintain records of occupational injuries and illnesses Report to OSHA within 8 hrs any incident that results in a fatality or in patient hospitalization of 3 or more employees Where to Find OSHA Standards Go to Regulations tab Part 1910 Occupational Safety and Health Standards 10

11 Dairy (Ag) Specific OSHA Standards temporary labor camps ( ) storage and handling of anhydrous ammonia ( (a) and (b)) logging operations ( ) slow moving vehicles ( ) hazard communication ( ) cadmium ( ) retention of Department of Transportation (DOT) markings, placards and labels ( ) 1928 Subparts C & D Safety for Ag Equipment (includes ROPS) Inspections, Citations & Penalties 11

12 OSHA Inspections OSHAct enables the Secretary of Labor to inspect job sites OSHA reps must show proper credentials before inspection Inspections can occur at any reasonable time and cannot be delayed Inspections can take place anywhere work is performed by EITHER employer or employee Inspection Advance Notice Inspections ALWAYS conducted without advance notice except for special circumstances Imminent danger Accident investigations Inspections after regular business hours Employer or employee representative are needed When delay >5 days is needed 12

13 OSHA Inspection Priorities Imminent danger situations = top priority Investigation of fatalities and accideents resulting in death or hospitaliztion of 3 or more employees (must be reported to OSHA within 8 hrs) Formal employee compaints Programmed inspections aimed at specific highhazard industries, workplaces, or occupations Follow up inspections Inspection Process Compliance officer displays official credentials and asks to meet with appropriate employer rep Opening conference Inspection (officer determines route and duration of inspection) Records will be inspected Hazard Communication Program Closing conference 13

14 Most Frequently Cited Standards in Dairy Process safety mgmt of highly hazardous chemicals ( ) Formaldehyde ( ) Hazardous waste operations and emergency response ( ) Hazard Communication ( ) Respiratory Protection ( ) Roll over protective structures (ROPS) ( ) Guarding floor and wall openings and holes ( ) Eye and face protection ( ) Medical services and first aid ( ) Guarding of field and farmstead equipment ( ) OSHA Penalties After Compliance Officer reports findings, Area Director determines whether he or she will issue citations and/or penalties Notice of proposed penalties by certified mail Employer must post a copy for 3 days or until the violation is abated 14

15 OSHA Penalties Less serious (direct relationship with job S&H but probably not cause death or serious harm) $0 $1,000 Substantial probability of death or harm $1,500 $7,000 Intentional or knowing violation $5,000 $70,000 Repeated violation up to $70,000 (with adjustments) Falsification of records $10,000 or more and jail Violation of posting requirements $7,000 Recordkeeping 15

16 Recordkeeping Part 1904 requires employers to record and report work related fatalities, injuries and illnesses OSHA 300 Injury and Illness Log OSHA 300a Summary of Injuries and Illnesses posted February 1 to April 30 OSHA 301 Injury and Illness Incident Report Safety Management 16

17 Safety Management: Owner Commitment Demonstrated owner commitment (lead by example) Clear expectations & performance standards Consistency when addressing worker behavior Designated safety director/coordinator Safety Management: Communications Established communication channels Employee meetings (regular, scheduled, & announced) Posters & bulletins Safety suggestion box All communications should be documented 17

18 Safety Management: Hazard Assessment & Control Periodical inspections Procedures for corrections If hazards occur or recur: reflection of control system Training is needed for new processes or machinery Safety Management: Accident Investigation Should be in writing Identify cause(s) of accidents or near misses Questions to ask: What happened Why did it happen What should be done What action has been taken 18

19 Safety Management: Planning, Rules & Procedures Simple, concise, and understandable May need to be translated Should be reviewed by all employees Address: Personal protective equipment, clothing, behavior, emergency procedures Safety practices for each specific job/area Discipline & reward procedures Emergency preparedness plans Hazardous chemicals (Hazard Communication Plan) Must have: Hazard Communication Established written, comprehensive communication program Container labeling Material Safety Data Sheets Employee training program List of hazardous chemicals in each work area Means to inform employees of hazards associated with chemicals 19

20 Safety Management: Worker Training Each worker must receive training No worker should undertake unsafe tasks Must understand chemical hazards Safeguards must be in place Workers should communicate with superiors All injuries & illnesses must be reported PPE must be used and properly maintained Safety animal handling training OSHA Training Standards Policy Statement 20

21 OSHA Training Standards Policy Statement Safety Management: Recordkeeping & Documentation Trainings Safety meetings/concerns Corrective actions Accident investigations All will serve as evidence of due diligence in safety compliance Workers should provide signatures of proof of their participations in trainings & meetings 21

22 Barriers to Safety Behavior Among Employees 1. Organizational support extent to which workers believe their management value their contributions & are concerned about their safety and health positive or negative organizational support influences workers interpretations of organizational motives underlying actions. managerial attitudes toward safety influence workers accident experiences, willingness to participate in health and safety programs, and safety behavior and injury experiences Barriers to Safety Behavior Among Employees 2. Supervisor safety support accomplished through on going communication exchanges between supervisors and workers Supervisors concerned about safety are likely to engage in conversations with workers regarding safety issues. providing information to subordinates or sharing attitudes or opinions regarding safety, supervisors act as driving force to affect workplace safety practices 22

23 Barriers to Safety Behavior Among Employees 3. Leadership exchange process between a leader (e.g., dairy owner or manager) and follower (e.g., dairy worker). Leaders reward followers when appropriate performance is achieved Greater perceptions of safety related leadership have been related to more positive safety climate perceptions, greater organizational level effectiveness, greater subordinate compliance with safety regulations, an increase in open and constructive communications about safety issues and a decrease in accidents Barriers to Safety Behavior Among Employees 4. Perceived fairness how workers perceive the fairness of work outcomes (e.g., reward), organizational procedures (e.g., execution of safety policies), and their treatment by management Perceptions of being fairly treated have been associated with workers engaging in more activities that go beyond their required work roles such as cooperative behaviors, and engaging in less counterproductive work behaviors 23

24 Summary Words and actions of dairy owners and managers reflect how much dairy farms care about workers safety and health at work. They also reflect how dairies execute safety policies and regulations People benefiting from others feel obligated to reciprocate. As a result, dairy workers would likely reciprocate the management support for safety by acting in a safe manner. Resources High Plains and Intermountain Center for Agricultural Health & Safety Other NIOSH sponsored Agricultural Health and Safety Centers (total of 9 centers: CA,WA,CO,IA,TX,KY,NY,WI,NE) US Department of Labor, Occupational Safety and Health Administration OSHA Compliance Assistance OSHA etools National Institute for Occupational Safety and Health (NIOSH), Safety and Health Resource Guide for Small Businesses Cal/OSHA Guide to Developing Your Workplace Injury and Illness Prevention Program Workers Compensation Insurance Providers 24

25 Contact David I. Douphrate University of Texas School of Public Health or High Plains & Intermountain Center for Agricultural Health and Safety Free Safety Training Videos Available! Belt Guarding 25

26 Belt Guarding Belt Guarding 26

27 Fan Blade Guarding Hazard Communication 27

28 Personal Protective Equipment Electrical Safety 28

29 Electrical Safety Other Issues 29

30 Electrical Safety Other Issues 30

31 Other Issues Questions 31

32 Fan Blade Guarding Good or Bad? Hazard Communication 32

33 Hazard Communication Hazard Communication 33

34 Hazard Communication Hazard Communication 34

35 Hazard Communication Personal Protective Equipment 35

36 Machine Guarding Most frequently cited standard across all industries Fan Blade Guarding Standard (a)(5) When periphery of blades < 7 feet above floor or working level, the blades shall be guarded Guard should have openings no larger than ½ inch 36

37 Fan Blade Guarding Is this fan adequately guarded according to OSHA? 7 feet from center of fan to ground Fan Blade Guarding 7 feet from center of fan to ground 37

38 Fan Blade Guarding Fan Blade Guarding

39 Belt Guarding How wide can these openings be? Belt Guarding 39

40 Distance a guard should be from a danger zone Distance of Opening from the Danger Zone Maximum width of Opening ½ to 1 ½ 1/4 1 ½ to 2 ½ 3/8 2 ½ to 3 ½ 1/2 3 ½ to 5 ½ 5/8 5 ½ to 6 ½ 3/4 6 ½ to 7 ½ 7/8 7 ½ to 12 ½ 1 1/4 12 ½ to 15 ½ 1 1/2 15 ½ to 17 ½ 1 7/8 17 ½ to 31 ½ 2 1/8 MACHINE SAFEGUARDING GENERAL BREAK 40

41 Belt Guarding Belt Guarding Good or Bad? 41

42 Belt Guarding Good or Bad? Belt Guarding Good or Bad? 42

43 Machine Guarding Electrical Safety (b) Examination, installation, and use of equipment-(1) Examination. Electrical equipment shall be free from recognized hazards that are likely to cause death or serious physical harm to employees. Safety of equipment shall be determined using the following considerations: (i) Suitability for installation... (ii) Mechanical strength and durability... (iii) Electrical insulation... (iv) Heating effects under conditions of use... (v) Arcing effects... (vi) Classification by type, size, voltage, current capacity, specific use... (vii) Other factors which contribute to the practical safeguarding of employees 43

44 Electrical Safety (e) Marking. Electrical equipment may not be used unless the manufacturer s name, trademark, or other descriptive marking by which the organization responsible for the product may be identified, is placed on the equipment. Other markings shall be provided giving voltage, current, wattage, or other ratings as necessary. The markings shall be of sufficient durability to withstand the environment involved Electrical Safety 44

45 Electrical Safety (f) Identification of disconnecting means and circuits. Each disconnecting means required by this subpart for motors and appliances shall be legibly marked to indicate its purpose, unless located and arranged so the purpose is evident. Each service, feeder, and branch circuit, at its disconnecting means or over-current device, shall be legibly marked to indicate its purpose, unless located and arranged so the purpose is evident. These markings shall be of sufficient durability to withstand the environment involved Electrical Safety 45

46 Electrical Safety (g)(1)(ii) Clear spaces. Working space may not be used for storage (g)(1)(iii) Access and entrance to working space. at least one entrance (g)(1)(iv) Front working space. Where there are live parts normally exposed, the working space in front of such equipment may not be less than 3 feet Electrical Safety (b)(1) Cabinets, boxes, & fittings-(1) Conductors entering boxes, cabinets, or fittings. Conductors entering boxes, cabinets, or fittings shall be protected from abrasion, and openings through which conductors enter shall be effectively closed. Unused openings in cabinets, boxes, & fittings shall also be effectively closed 46

47 Electrical Safety Good or Bad? Electrical Safety Good or Bad? 47

48 Electrical Safety Good or Bad? Electrical Safety 48

49 Electrical Safety Confined Space Confined space means a space that: Is large enough and so configured that an employee can bodily enter and perform assigned work; and Has limited or restricted means for entry or exit; and Is not designed for continuous employee occupancy 49

50 Confined Space Permit-required confined space. (permit space) means a confined space that has one or more of the following characteristics: (1) Contains or has a potential to contain a hazardous atmosphere. (2) Contains a material that has the potential for engulfing an entrant. Confined Space Flammable gas, vapor or mist Airborne combustible dust Too much or too little oxygen Acute acting air contaminants, and Other atmospheric conditions IDLH 50

51 Permit Required Confined Space Permit required confined space program (permit space program) means the employer s overall program for controlling, and, where appropriate, for protecting employees from, permit space hazards and for regulating employee entry into permit spaces. Permit Required Confined Space 51

52 Lockout/Tagout (a) Scope, application and purpose (1) (i) This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy could cause injury to employees. This standard establishes minimum performance requirements for the control of such hazardous energy. Lockout/Tagout (a)(2) Application. (i) This standard applies to the control of energy during servicing and/or maintenance of machines and equipment. 52

53 Lockout/Tagout Other Issues 53

54 Other Issues Animal Handling General Duty Clause 54

55 OSHA Website: Resources Regulations, inspections, citations, stats, publications HICAHS Website: HICAHS Phone: State OSHA Consultation Dairy Research & Outreach Livestock-handling injuries Among Dairy Workers: An Analysis of Workers Compensation Data Injury Risk Analysis in Large Herd Dairies Full-Shift Direct Measurement of Exposure to Muscle Forces Among Large-Herd Dairy Parlor Workers Full-Shift Direct Measurement of Exposure to Upper Extremity Awkward Postures Among Large-Herd Dairy Parlor Workers Prevalence of Median Mono-Neuropathy Across the Carpal Tunnel Among Large-Herd Dairy Parlor Workers Dairy Safety Management Using Lean Six Sigma High Plains and Mountain Region Dairy Health and Safety Workshop I-29 OSHA Training Dairy OSHA 10 Certification Training 55

56 Future Workshops Safety Programs Means of Egress Occupational Health Hazardous Material Personal Protective Equipment Confine Space Lockout/Tagout Medical & First Aid Tools Fire Protection Material Handling Machine Guarding Electrical Bloodborne Pathogens Hazardous Communication Toxic & Hazardous Substances Welding 56