Farming is routinely targeted more than other industries for safety compliance. Failure to adhere to ever-growing safety regulations can put your employees at risk, resulting in costly fines and legal consequences. As a farm owner or HR manager in agriculture, ensuring a safe and compliant workplace should be a top priority. In this blog post, I'll examine the top 10 agricultural safety violations cited by the Washington State Department of Labor and Industries (but other states have similar regulations!) in 2023, along with practical suggestions on complying with these rules.
1. Foreman-crew Safety Meetings (cited 189 times)
This rule requires you to conduct safety meetings at least monthly or whenever significant changes in job assignments occur. Tailor these meetings to the specific operations or activities occurring at the time. Maintain minutes documenting the subjects discussed, and attendance for one year.
Suggestion: Use Harvust's automated safety meeting programs! We'll choose the best topics for your farm and send the training to your workers' phones to complete, resulting in better attendance and recordkeeping so you never get tripped up on a technicality.
2. Accident Prevention Program (cited 175 times)
You must develop and implement a written accident prevention program tailored to your agricultural operation and the types of hazards involved. This program must cover injury and illness reporting procedures, personal protective equipment (PPE) usage, emergency response plans, and hazardous chemical identification and safe handling.
Suggestion: Consult with safety professionals or industry experts like the Washington State Farm Bureau to develop a comprehensive accident prevention program that addresses the specific risks associated with your operations and for each location. Regularly review and update the program to reflect changes in operations or regulations.
3. Written Hazard Communication Program (cited 101 times)
This rule mandates that you develop, implement, and maintain a written hazard communication program detailing how they will comply with labeling, safety data sheet (SDS) requirements, and employee information and training. The program must include a list of hazardous chemicals in the workplace and methods for informing employees about non-routine tasks involving dangerous chemicals.
Suggestion: Conduct a thorough inventory of all hazardous chemicals used in your operation and develop a written hazard communication program outlining labeling, SDS management, and employee training procedures. Regularly update the chemical inventory and ensure SDSs are readily accessible to employees. SDSs can be digital and still comply with this rule!
4. Employee Information and Training (cited 96 times)
Regarding the above point, you can't just have a haz-com program! You must effectively inform and train employees regarding hazardous chemicals in their work area. This training should cover detection methods, hazards associated with the substances, protective measures, labeling systems, and how to access SDSs.
Suggestion: After you have a comprehensive hazard communication program, ensure that all new employees receive this training upon initial assignment and provide refresher training whenever new chemical hazards are introduced or when employees demonstrate a lack of understanding.
5. Fire Protection; Exit Routes (cited 93 times)
This rule requires employers to inspect, maintain, and test portable fire extinguishers. Monthly visual inspections, annual maintenance checks, and hydrostatic testing (every 6-12 years, depending on the extinguisher type) are mandated. Proper exit routes and emergency evacuation procedures must also be established.
Suggestion: Implement a rigorous fire extinguisher inspection and maintenance program, keeping detailed records of all activities. Conduct regular fire safety training for employees and ensure that exit routes are marked and free from obstructions.
6. Additional Requirements to Protect Temporary Worker Housing Occupants from COVID-19 (cited 91 times)
This rule outlines specific requirements for protecting temporary worker housing occupants from COVID-19, including physical distancing, enhanced cleaning and disinfection protocols, and providing adequate personal protective equipment (PPE).
Suggestion: Proactively consult with the Department of Health and the L&I consultation department regarding COVID-19 prevention measures in temporary worker housing. Even though we're more or less "over COVID" I reccomend you still attend L&I outreach events like the Ag Safety and Health Forum to stay up-to-date on these expanding rules. You may be surprised what COVID-adjacent rules might get snuck in!
7. Requirement for Safe Place Standard (cited 89 times)
Farms and packing operations must furnish a workplace free from recognized controllable hazards likely to cause severe injury or death. You must also provide and require the use of necessary safety devices and safeguards and prohibit employees from engaging in unsafe duties or entering hazardous areas. It's a general rule, so it's no wonder it was cited so much!
Suggestion: Make sure all of your safety equipment is working, and ensure your supervisors aren't interfering with workers' use of safety equipment. Finally, under no circumstances should you allow intoxicated employees on the worksite! Preventing this can be tricky if you have workers living in housing at the ranch, so communication is vital in this scenario.
8. First Aid Rule Summary (cited 82 times)
This rule requires you to ensure that first-aid-trained personnel are available to provide quick and effective first aid in the absence of an infirmary, clinic, or hospital within close proximity to the workplace.
Suggestion: Provide first aid training to a sufficient number of employees to ensure adequate coverage across all shifts and work areas. You can arrange for a first aid training organization, like Nick Romero's, to come on-site, or you can mandate employees get themselves certified, but in each case, you need to pay for all costs and time involved. Maintain well-stocked first aid kits and ensure they are readily accessible to employees. This can be tough to track, given how many ranches and buildings we have in our companies. One of our customers replaced their fixed first aid kit locations with mobile kits carried in the vehicle of each supervisor or farm manager.
9. Provide Medical Evaluations for Respirators (cited 76 times)
You must follow a specific medical evaluation process for employees required to use respirators or who voluntarily use non-filtering facepiece respirators. This includes identifying a licensed healthcare professional (LHCP) to perform the evaluations and providing them with relevant information about the respirators and their use.
Suggestion: Develop a comprehensive respiratory protection program with the required medical evaluation process. Work closely with an LHCP to ensure compliance with all evaluation requirements and maintain appropriate records.
10. Pesticides Recordkeeping (cited 57 times)
If you apply pesticides, you must maintain detailed records of each application, including location, date, time, product information, application rates, wind conditions, and applicator information. Pesticide storage inventory and purchase records must also be maintained.
Suggestion: Implement a robust pesticide recordkeeping system that captures all required information for each application. Your spray rig manufacturer or chemical supplier may already offer such a system. The hard part is making sure that it is actually filled out. We've seen success when you designate a responsible individual to maintain accurate and up-to-date records.
By understanding and addressing these top agricultural safety violations, you can create a safer work environment for your employees and avoid costly fines and legal repercussions. Regularly reviewing and updating your safety programs, providing comprehensive employee training, and fostering a safety culture should be top priorities for any responsible agricultural employer.
