OSHA inspection results a reservoir for learning
Want to avoid the trauma of a disabling injury of death of a farm employee or family member that might also trigger a visit and penalties from the federal Occupational Health and Safety Administration?
Then take some hints from the results of the 15 OSHA inspections of Wisconsin dairy farms in 2012 that were conducted under the title of OSHA's Local Emphasis Program (LEP), Manitowoc County Extension Service dairy agent Scott Gunderson advises.
Those inspections all involved dairy farms with 11 or more non-family employees at any time during a year, he points out.
At the annual meeting of the county's Forage Council, Gunderson reviewed the reported results from the 30 attempted (and 15 completed) inspections by OSHA's Wisconsin district offices at Madison, Eau Claire, Milwaukee, and Appleton.
He noted that all four inspections carried out by the Appleton office were the result of complaints (probably by farm employees) filed with that office.
Based on data current as of early December 2012, two of the inspected farms were found to be in full compliance with OSHA's standards for safety and health.
Ten others were found to have one or more violations and were issued citations that incur monetary penalties while the other three were in various stages of the response or evaluation process.
Gunderson said the LEP in Wisconsin was prompted by the death of a dairy farm employee in a skidsteer accident at a manure storage unit.
Among the dozen or more on-farm accidental deaths that typically occur in Wisconsin annually, some have occurred in vertical feed mixers and because of uncovered power take-off units, he indicated.
Under OSHA's rules, a violation occurs if the agency's standard applies to the working conditions, the terms of the standard are not being met, employees were exposed to the condition, and employer could reasonably have been aware of the situation, Gunderson explained. He said all four of those elements are needed in order to justify a citation for a violation.
For the 10 farms cited with violations by early December of 2012, the total original assessment of penalties was $37,235. Following negotiations and followup abatement by those operators, the final penalty total was $22,865.
Among the practices or conditions receiving citations in the 2012 inspections, there were nine for inadequate communication about hazards, three for not maintaining records about injuries, two each involving belts or pulleys, training on operating tractors, guard structures at manure push-off points, and one each for animal handling, chemical splash to eyes, and power take-off guards.
Other items that OSHA addressed were back-up alarms on skidsteers, lifelines, fencing, and signage at manure storage facilities, protection against falls at bunker silos, confined spaces in grain bins, and personal protective equipment when handling hazardous chemicals.
Gunderson noted that emergency eye wash stations can be purchased for about $100.
The potential causes of injury or death also include electric power systems, exposure to noise, controls on the energy source of power equipment when it is being serviced, and not having escape routes or safety spots when handling livestock, Gunderson observed.
He said the Extension Service has a compact disk and binder on worker positioning when moving cattle that costs $50.
To reduce the chances of receiving an OSHA citation, place engineering and manufacturer-supplied safety controls on equipment, hold meetings at which safe working practices are explained and demonstrated, enforce the use of personal protective gear, and provide training as needed, Gunderson stated.
He also recommends a safety training video developed by Tom Wall.
Other pro-active practices that OSHA likes to see are the documenting of measures taken to promote on-farm worker safety and health, the completion of accident and other incident reports, frequent walk-throughs by farm owners or supervisors, keeping current with industry practices, and seeking a job safety analysis by an outside party, Gunderson indicated.
For more information, dairy farmers who are subject to OSHA oversight and possible inspections due to having sufficient employee numbers are invited to subscribe to the e-mail alerts provided on the http://fyi.uwex.edu/agsafety website, which is operated by the University of Wisconsin Center for Agricultural Safety and Health.