The Syracuse, New York, office of the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) will be implementing a “Local Emphasis Program” consisting of random, unannounced dairy farm safety compliance inspections beginning in July.
OSHA says it can inspect businesses based on four priorities: Imminent danger; catastrophes and fatal accidents; complaints and referrals; and programmed inspections. (Download a PDF of the notice, 849 KB.)
Farms subject to programmed inspections are those that have more than 10 employees, not including immediate family members, at any time in the 12 months preceding the inspection (part-time employees count as “1 employee”).
Issues found must be corrected within 30-45 days or enforcement action can be taken.
Read previous coverage of the inspection program.
Based on Wisconsin’s experience with a similar enforcement effort, few farms passed through inspections without at least some fines. Average fines in that state have varied from farm to farm. Therefore it is important to make safety and compliance a priority. Be particularly aware of the need for recordkeeping. Be sure to document all safety training and communications with employees, even if it is informal.
Several organizations are working with farms to help them get ready for compliance inspections:
- New York Center for Agricultural Medicine and Health has prepared work programs for farms to complete, which give ideas to help become OSHA compliant.
- Farm Credit East, Northeast Dairy Producers Association, Inc., New York Farm Bureau and PRO-DAIRY hosted a webinar to help dairy farms understand OSHA requirements. Ron Williams, from the U.S. Department of Labor – OSHA based in Syracuse, explained what is involved with an OSHA audit and provided information on 12 key areas of concern for OSHA, called the "dairy dozen."
All dairy farmers should know whether they fall under OSHA enforcement authority and have a plan for what to do if inspectors show up.
Key items that OSHA will be reviewing, sometimes called the “dairy dozen”:
- Manure storage facilities and collection structures
- Dairy bull and cow behavior
- Electrical systems
- Skid-steer loader operation
- Tractor operation
- Guarding of power take-offs
- Guarding of other power transmission and functional components
- Hazardous energy control while performing servicing and maintenance on equipment
- Hazard communication
- Confined spaces
- Horizontal bunker silos
- Dangerous noise levels PD
