OSHA: What You Need To Know

Last year OSHA approved a Local Emphasis Program (LEP) for Wisconsin allowing for OSHA inspections on farms that have had more than 10 non-family member employees in the last 12 months OR have had an active temporary labor camp in the last 12 months. This exempts small farming operations not meeting either requirement.  

The LEP calls for random inspections by OSHA Compliance Safety and Health Officers (CSHO) on 12 farms around the state. These inspections will focus on 12 common safety and health hazards prevalent on dairy farms.

Scope: Inspections are to include facilities and operations where farm employees are engaged in the dairy farm operations, including but not limited to: milking parlor, dairy cattle barns, equipment maintenance sheds, storage sheds, manure storage facilities and collection structures, horizontal silos, vertical silos, and grain storage.

12 Common Hazardous Activities

   1. Manure Storage Facilities and Collection Structures

   2. Dairy Bull and Cow Behavior/Worker Positioning

   3. Electrical Systems

   4. Skid-Steer Loader Operation

   5. Tractor Operation

   6. Guarding of Power Take-Offs (PTOs)

   7. Guarding of other Power Transmission and Functional Components

   8. Hazardous Energy Control while performing servicing and maint.

   9. Hazard Communication

  10. Confined Spaces

  11. Horizontal Bunker Silos

  12. Noise

Types of Inspections: Inspections are comprehensive safety inspections, unless the compliance officer sees a potential health hazard. Unprogrammed activities (such as complaints, fatalities, catastrophes, referrals) regarding covered dairy farm operations will be expanded to include the procedures in the LEP.

Citations: Safety and health hazard exposure not covered under 29 CFR 1928 (Agriculture Standards) would be evaluated under Section 5(a)(1) of the Occupational Safety and Health Act of 1970 (OSHA Act of 1970) that provides "Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees."

Document Review:  As part of the inspection process, an employer's OSHA 300 Injury and Illness Logs for current and previous 3 years, and the corresponding OSHA 300A Summary Forms, as well as any and all employer provided safety and health programs and training may be requested.

For more information on Hazard Communications, read our blog or dairy update article.