Staying awake in the break room

Employees gather for yet another safety talk, anticipating boredom. Safety talks can be sleeper events, but when there’s injury or death on the farm, safety suddenly becomes the main conversation – for a short time. Incidents can be prevented by familiarizing employees and family members with farm safety standards regularly.

Florence Becot, Ph.D., is an associate professor in agricultural safety and health and lead for Penn State’s Agricultural Safety & Health program. She recently presented information on farm safety and risk management.

Becot outlined two approaches for managing farm safety: 1) An incident occurs, then it’s determined what happened and action is taken to avoid the same incident in the future. 2) Identify hazards, determine how bad it could be and put preventive practices in place.

“The recommendation is often to shift from a focus on regulatory compliance to managing risk,” Becot said. “It’s simple to think ‘We’ll do what we’re required to do by regulation.’ A lot of things farms are exempt from are about managing risks. That means focusing on identifying potential hazards, then putting proper controls in place.”

While there is no single way to create a plan, the key is using a consistent and systematic approach.

Becot described a farm safety and health plan as “a written, practical document that sets out processes and practices to help prevent injuries, illness and fatalities on the farm.”

“It can also include how to communicate hazards to staff and the public,” Becot said. “Often plans are focused on workers, but for those who have operations where the public comes to the farm, that information can be included in the plan. Again, the focus is on a proactive approach to identify, then manage hazards in the workplace.”

She outlined the five components for a safety plan, beginning with management leadership. “This is the general idea of the safety plan and how it is implemented,” she said. “Workers can participate as well.”

Hazard identification and assessment help determine what could go wrong, how likely is it to happen and how bad it could get. These aspects are the most difficult to identify but have the most potential to initiate change.

“A safety plan often includes education and training,” Becot said. “What kind of training will you do with workers? What’s the content? And how often will you do it?”

Another component is evaluation and improvement – determine what’s working and change what isn’t.

Like every other aspect of farming, there is no one-size-fits-all for safety planning. Creating a plan is an intuitive process, so Becot recommends starting small. If the plan is working, expand over time.

Everyone on the farm should participate in developing the plan to introduce different experiences and perspectives. Each area on the farm has different hazards, so including everyone will help identify all areas of potential risk.

“If you are going to spend time to develop a farm safety plan, you need to make sure everyone is on board as much as possible, otherwise it will be harder to implement,” Becot said.

Most people have different views about what is safe and not safe on the farm. While Occupational Safety & Health Organization (OSHA) regulations don’t apply to some farms, all farms are subject to certain OSHA rules. Becot references OSHA law that says employers have a responsibility to provide a safe workplace.

“The employer should examine the workplace conditions to make sure they conform to applicable OHSA standards, identifying risks and addressing them,” Becot said. “OSHA also says that an employer’s responsibility is to make sure employees have and use safe tools and equipment, and that those are properly maintained. It involves paying attention and doing an inventory several times a year, then checking in with folks about how things are working. OSHA encourages all employers to adopt a safety and health program. It isn’t required, but most safety and health programs are based on a common set of key elements which include management leadership, worker participation and a systematic approach to finding and fixing hazards.”

Becot clarified that OSHA doesn’t apply to self-employed individuals with no workers, and that the agricultural exemption for OSHA is more complicated. Farms with fewer than 10 employees, not counting family members, are under the ag exemption. However, there are a few areas OSHA can check.

“You aren’t exempt from everything,” she said. “You’re still required to adhere to the hazardous occupations order for agriculture. This is if you are going to hire workers under 16 who are non-family members. There are rules about what they can and cannot do.”

Another rule that applies to everyone, no matter the number of employees, are Worker Protection Standards (WPS) related to pesticide regulations. Employers are also required to report fatalities or severe injuries. There is a recordkeeping exemption unless OSHA requests records, but they may be required if there is an injury that requires investigation.

Farms under the ag exemption cannot be inspected for compliance – an OSHA inspector cannot visit a farm and ask how things are going.

“However, you can be inspected under the General Duty Clause which says that employers must protect their employees from any serious hazards once they are aware of it, whether OSHA rules specifically address it or not,” Becot said.

There are four conditions OSHA must prove to invoke the General Duty Clause and visit the farm for an inspection. This usually occurs if there is a fatality or major injury.

“The employer failed to keep the workplace free of a hazard to which its employees were exposed,” Becot said. “The cited hazard was recognized (the employer knew about it), the hazard was causing or likely to cause death or serious physical harm and a feasible and practical method to correct the risk was available.” The last point is critical – it triggers the General Duty Clause.

These points are important when it comes to putting together a safety plan. Becot also cautions employers to be aware of recognizing a major hazard but not correcting it.

by Sally Colby