The heat and hectic pace of summer make unannounced guests on the farm less than convenient. Manners matter, and a phone call or text message makes all the difference for a pleasant visit. There is one case, though, where expecting the unexpected can save you stress, money, and potential injuries at your operation, and that’s anticipating the arrival of an OSHA inspector. They don’t need reason, observations, or cause to pop by and make sure you and your employees are compliant with safety standards, but you can plan ahead by reviewing your policies and practices.
There have been an increased number of random inspections at farms throughout the Willamette Valley and Columbia Gorge, and they have been focused on pesticide safety. Reports from Oregon Aglink members suggest that OSHA is paying close attention to inspecting pesticide storage, PPE, decontamination, equipment, training and records.
Whether or not the OSHA inspector has your farm or ranch on the list for a visit, here is the helpful list to look over with your employees and prioritize updating at your work site:
Storage
Having a safe and compliant storage area for your pesticides means the space is lockable, has cleanable surfaces, containment, category organization, and signage. Want to dig deeper? Here are the guidelines recommended for assessing your space:
- Lock it Up: The storage location must be locked every time you come and go, even if you are spraying that day. Restricted Use chemicals trigger higher levels of scrutiny, so plan it out– do you want them in a separate spot like a locking cabinet, or do you want to lock the whole location
- Can You Clean It? All chemicals need to be stored on a surface where spills can be cleaned and not seep. Think metal, vinyl, or sealed wood. The storage space also needs containment for potential spills, whether that means the whole shelf has a lip or chemicals are set in individual trays or bins.
- Organize It: chemicals should be separated by dry and wet as well as by use to limit dangerous potential interactions. So, granular chemicals should never be stored under liquid in case of a leak and herbicides should be separate from insecticides and so forth.
- Label It: The separated shelves and bins in the last point? Label them. The enclosed space with all the shelves and bins? Post up a sign, ideally bilingual, identifying that chemicals are inside, such as “Danger: Pesticides.” Consider posting National Fire Protection Association placards to indicate hazards for first responders, especially for products that could react with water or be hazardous with heat and smoke.
PPE & Decontamination: “The label is the law,” so what are your labels saying you need on hand in case of contamination? Of course this varies based on products being used, but OSHA inspectors want to see that you have the correct protective equipment and know what to use and when. For example, if you’re using Paraquat, you need to have a fifteen minute eyewash and emergency shower and be able to show them those are accessible to the pesticide applicator. Inspectors are also asking about even less dangerous products and for proof of PPE and decontamination protocols across any chemicals stored and used on your farm.
Equipment: Does your sprayer and any other applicator equipment have proper shielding in place, lights, SMVs, and safety chains? Make sure all equipment gets decontaminated after pesticide use so nothing sits with residue on it.
Training: Any farm spraying a crop to be harvested needs an annual training for Worker Protection Standard (WPS). annual respiratory protection training, hazard communication training, how to read SDS labels, heat safety training during June-September. OSHA inspectors have recently been asking to review training records and interviewing employees about training
Records: Make sure your central posting is up to date with your recording log as part of SDS requirements and that your SDS book is current and up to date as well.
As a bonus best practice, remember to Communicate with your neighbors when you make plans to spray, especially for aerial application. If an ounce of prevention is worth a pound of cure, a quick text message is worth a month of emails, or worse, after the fact. As a community, we can work to minimize conflict ahead of time and protect our reputation as an industry.
By Allison Cloo and Eric Lloyd