MARTIETTA, NY — Want to breathe easier about OSHA compliance? Try a voluntary safety audit. Earlier this year, Volles Farm hosted a farm safety workshop featuring Keith Gillette and Michael Cappelli, supervising safety & health consultant and senior safety and health consultant, respectively, for the New York Department of Labor.
Gillette said free farm safety audits were funded by a variety of government agencies when OSHA became aware that many small farms could not afford to employ a full-time safety employee. Any farm of fewer than 250 employees per site and 500 nationwide qualifies for a free safety audit. New York Center for Agricultural Medicine and Health (NYCAMH) and the New York Department of Labor both offer free farm safety audits.
The programs are voluntary unless part of a settlement with OSHA. Auditors are trained the same as OSHA inspectors, though their visits are confidential, unless part of a compliance situation.
“We don’t share with the media or inspectors but you agree to correct any serious hazards,” Gillette said. “If you don’t by the date we specify, we will contact OSHA.”
Farmers can limit the audit to certain functions, areas, buildings or portions of the farm. If auditor finds many areas of non-compliance, the farmer can work on a few areas at a time and continue the audit later, as resources may be strained to tackle everything at once.
Farms undergoing a safety audit are exempt from any OSHA inspection while they’re in the midst of an open consultation with a safety auditor.
“They may come back later, but for the time being, you’re off the hook,” Gillette said.
The free service is “first come, first served” and because so many farms use the service, auditors for both NYCAMH and the Department of Labor are booked for months in advance.
Gillette said farmers need to plan for a time when they can spare a key employee to walk the farm with the auditor so there is a better understanding of what needs improving.
Also, some items are borderline.
“It’s like driving at 57 miles per hour,” Gillette said. “Will I get a ticket? Maybe, if the officer is having a bad day. OSHA people see a lot of bad things that can cause fatalities. That’s why they want to get things done right.
“We’re invited and trying to be helpful, so you want us to come out first.”
In addition to making observations, safety consultants also ask farmers about their operation, written safety programs, and give feedback on their safety protocols, according to Cappelli.
“You need to know what standards OSHA will expect,” Cappelli said.
He said the “Dairy Dozen” list can help farmers know what they should pay special attention to:
- Manure storage facilities and collection structures
- Dairy bull and cow behavior/worker positioning
- Electrical systems
- Skid loaders
- Tractor operation
- Guarding of PTOs
- Guarding of power transmission and functional components
- Hazardous energy control while servicing or maintaining equipment
- Hazard communication
- Confined space
- Horizontal bunker silos
A manure lagoon, for example, should include a secure perimeter barrier and warning sign.
Cappelli said he doesn’t experience many problems with dairy cow behavior as most of his farm guides keep him — as well as other visitors — out of animal holding areas.
Electrical safety violations are common on farms, according to Gillette. These include electrical boxes without covers, wiring that’s hanging, bare wires, transformers without lids, and no cover for circuit breaker.
Many of these kinds of issues don’t happen overnight.
“As a small farm gets bigger, layers and layers of new equipment is added,” Cappelli explained. “As that happens, it may not be compliant.”
As the operation hires new employees, keeping up with training can help the farm stay in compliance. Training for using machinery, tractors, skid steers and personal protective equipment should all be part of employees’ orientation to the farm, as applicable.
By documenting all employee training, farms can protect themselves better from liability when accidents happen.
Cappelli added that farmers also need to develop a lock-out protocol and document its use so employees can safely repair equipment.
Material safety data sheets (MSDS) must be properly shared with employees through a MSDS book so they know their risks, proper use, how to protect themselves while using hazardous materials and first aid. Cappelli said every time the farm receives a delivery of hazardous materials, the MSDS should go right in the book.
Cappelli mentioned that confined spaces — areas not designed for continual occupancy — must bear signs and proper access restriction as needed.
Noise issues should also be addressed by personal protection equipment (PPE), along with documented training on how and when to use PPE.
“We can help when establishing farm safety programs,” he added. “We give farmers feedback. We give ideas on rectifying standards.”
The South Central New York Dairy and Field Crops Team from Cornell Cooperative Extension hosted the workshop.