Hazard communication on the farm

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Chase Pagel doesn’t just talk about safety, she lives it. As the safety coordinator for Pagel’s Family Business, part of which includes the largest privately owned dairy farm in Wisconsin, Pagel is responsible for both employee and visitor safety. She recently provided information on the top OSHA violations for Dairy Girl Network.

On the OSHA website, Pagel found the most common violations resulting from audits on dairy farms. Penalties for violations averaged $5,200/facility and were as high as $14,500/violation. But that’s only the monetary aspect – the true cost of an unsafe workplace can be much higher.

Some farms don’t fall under OSHA regulations, but it’s still worth following their safety recommendations to prevent accidents and injuries. Some of the most common OSHA violations involve lockout/tagout, heat-related illnesses, operating equipment without appropriate permits, confined spaces, shafts and collars (guards), seat belts, incorrect reporting of establishment size, guards on equipment, cylinder safety, improper use of ROPS, unsafe walkways, forklifts, safety for abrasive wheels, poor lighting and unsafe work conditions.

Most infractions can be categorized, but Pagel noted that if OSHA auditors find something unsafe that isn’t listed in OSHA standards, the establishment can still be cited for unsafe work conditions.

While the violations listed above are common, hazard communication tops the list. A good hazard communication program is one of the most important aspects of farm safety, and includes managing chemical inventory, labeling, pictograms, safety data sheets (SDS) and written programs for hazard communication and training.

Pagel is responsible for keeping an inventory of more than 3,000 chemicals and admitted that maintaining that inventory is tough. “We start each year with a chemical inventory,” she said. “We take pictures of the chemicals as we’re going through them and download the photos to a computer. As new chemicals come in, we want our managers and staff to let us know what those chemicals are and which departments they’re in.”

Chemicals are inventoried by department. For the milking parlor, there’s an inventory of all chemicals in the parlor as well as those in any barns attached to the parlor. Pagel maintains a separate inventory for the shop and other areas on the farm.

As the chemical inventory is conducted, there should be an SDS for each chemical inventoried. “Different brands have different SDS, so it’s important to have an SDS for each brand,” said Pagel. “I keep safety data sheets in a book by department.” It’s important that all SDS are accessible either digitally or physically, to all employees at all times.

Products that are no longer being used should still have an SDS. “Keep the SDS for 30 years after you retire [a product],” said Pagel. “Even if you only have a chemical for two years, you need to have the SDS for 30 years.” The SDS for retired chemicals don’t have to be accessible but should be safely stored for reference.

Pagel suggested contacting vendors to obtain the SDS for products. For products purchased off the shelf, use the label for basic information such as the product name and manufacturer, then search for that product’s SDS online. Although OSHA doesn’t require it, it’s useful to have the SDS available in other languages.

Labeling is an important aspect of hazard communication. All chemical containers must be labeled, including secondary containment units (any type of container you’re putting a chemical in that isn’t the original container).

Pagel described two specific circumstances under which it’s acceptable to use a secondary containment unit. One is to completely remove the original label and immediately put a new, accurate label on the container. The other situation for a secondary containment unit is if one person will have full control of the chemical the entire time the chemical is in it. Full control means the container cannot be put down and out of the person’s direct supervision at any time. Pagel suggested using a secondary container only if it has been properly relabeled.

Farms should have a clear policy for secondary container units – are they allowed or not? If so, who is creating labels? Make sure employees know who’s in charge of such a program and who they can go to with questions.

Labels for secondary containment units can be created from the SDS sheet, using the information in the first section of the sheet. The most important text includes the chemical name, emergency phone numbers, hazard words, pictograms, warnings and any other necessary information.

Pagel admitted labeling can be difficult in situations such as dip cups in a milking parlor because it’s difficult to make a label stick on such containers. For this, she suggested taking a picture of the dip cup, putting the picture with a label on or next to the dip cup, laminating the picture and label and hanging it where the dip cup is stored. When not in use, the dip cup must always be stored in the same place as the label.

The farm’s hazard communication program includes any measures taken for communicating all hazards that threaten health and safety. This program should include the person responsible for the program, SDS, labeling, chemicals, inventory, labels and employee training.

OSHA’s Hazard Communication Standard requires the use of pictograms to alert users of any chemical hazard exposures. The OSHA website includes a printable pictogram guide. Pagel provides new hires with a printed sheet of the pictograms, and the pictograms are also on posters. Part of Pagel’s training program involves teaching employees the meaning of each pictogram, which enables them to recognize potential hazards throughout the farm. It’s also a good way to communicate hazards with non-English speaking employees.

It’s important to make sure staff is aware of all hazard communication measures and training. Pagel said that during an audit, OSHA will talk to staff and ask many questions including “Do you have SDS sheets, and were you trained for this?”

Pagel said safety training for employees should include SDS, chemical storage, pictograms and proper PPE. “Let employees know if there is an emergency, they can provide the entire SDS book or show [emergency personnel] the SDS sheet they may need,” she said. “As we put our SDS books together, because the SDS can be hard to read, I make a cover sheet for each SDS with a picture of the chemical and put them in alphabetical order. Staff can look at the chemical and match the picture to the chemical.”

Visit the OSHA website for more information on hazard communication and printable pictograms.

by Sally Colby

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