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On the Safe Side

Nov 18, 2012

How to prepare your dairy for an OSHA audit.

ChuckSchwartau photoBy Chuck Schwartau, University of Minnesota Extension

It’s a long held concept that employers should expect that a fair day’s work and a fair day’s pay go hand in hand. What is sometimes forgotten is that the worker should also expect a safe place in which to do that work. Occupational Safety and Health Administration (OSHA) audits are fairly common in many industries, but in agriculture, they have been rare and often conducted only after a fatal incident. In some regions that is changing, and dairy farms are more often the subject of an OSHA audit.

An audit doesn’t have to be something a farm should fear, assuming the farm has a safety plan in place that meets basic requirements. A complete, detailed plan can take significant time to develop and implement, but basic concepts can be implemented rather quickly and at minimal cost.

An Australian program called “The People in Dairy” suggests “SAFER” Principles for safety:

See - identify hazards to health and safety on the farm
Assess - decide the risk associated with the hazard
Fix - take appropriate action to control the risk
Evaluate - check to be sure your controls are effective
Record - record actions you take or plan

Similar plans are part of OSHA training programs that help industries of all kinds meet the requirements for a safe workplace.

“Seeing” hazards is a job in which everyone on the farm must participate. There are obvious, large hazards on most farms, but there are also many small and insignificant appearing ones that need to be address as well. Make it easy for workers to report and record hazards as they are seen so someone on the farm can “Assess” them promptly.

An assessment should be conducted to establish the severity of the hazard and determine appropriate action steps -- the “Fix.”

Action steps don’t always mean expensive fixes or changes, however. High risk hazards should be eliminated if at all possible, but many hazards can be addressed in different ways. The methods and priorities for controlling risks are often addressed in the following order:

1. Eliminate the hazard when possible. This might mean replacing a product or piece of equipment or totally eliminating it from the farm.
2. Substitution is another option. You might be able to replace the hazard with something else less hazardous that still does the job. The substitution might be equipment or a different procedure.
3. Engineering might minimize the hazard. Installation of guards, railings, safety switches or building proper storage units often eliminates or minimizes the hazard.
4. Safe work practices and procedural changes may minimize the risk to workers. A set of well-written standard operating procedures (SOPs) should include practices that avoid or minimize risks.
5. Finally, personal protective equipment (PPE) is a last measure to be considered. After everything else is done and there is still some degree of hazard, provide proper PPE for workers and insist it be used as it is intended. PPE’s on a shelf, in a cupboard or hanging on a hook are no protection.

“Evaluate” is the fourth stage of the SAFER program. Check the impact of the "fix" that was implemented. It is important for employers to check back and be sure the steps taken have achieved the desired outcome. Did hazard elimination or guarding get done? Were SOP’s developed and are they being followed to eliminate or minimize the hazard? Is PPE being used all the time? If any of these questions leave doubt that the hazard has been fully addressed, you know your job of providing a safe workplace isn’t quite done and you need to look again at the action step.

“Record” all the actions you take or plan to take. This will provide the documentation that would probably be requested if your farm is ever the subject of an OSHA audit.

The most important factor to achieve success is the people on the farm. If the people aren’t willing to work with you on safety, a good safety program will be difficult to implement. If the workers are engaged in the plan development, they are much more likely to implement it.

Suggested steps to worker engagement are:
• Work with the workers to identify hazards and have them help with assessment.
• Regularly include health and safety discussions in staff meetings.
• Record workers’ input and actions taken on any safety items. This step will help demonstrate your effort to comply with regulations.
• Be a good role model for your workers.

I very deliberately used the term “workers” rather than “employees” because the term worker also includes all owners and managers on the farm, not just the people out in the barns day after day. A culture of safety on the dairy means everyone needs to take the issue seriously, and everyone needs to practice safety all the time. If you don’t work safely all the time, why should others on the farm?

Minnesota and Wisconsin are offering dairy farm safety programs this winter (2012-13) to help farms achieve the goal of a safer workplace. Be watching for dates and locations. Many other states around the country have similar programs, so watch for them, or ask your Extension Service or insurer about programs in your area.

Chuck Schwartau is an Extension Educator at the University of Minnesota. Contact him at
cschwart@umn.edu.

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