[2014 | Keywords: Regulatory Compliance]
Agricultural safety awareness is on the rise in the United States, especially as we recognize National Farm Safety & Health Week September 21-27. Fatalities in the agricultural industry have climbed to the number two spot on the list of industries with the most annual fatalities, just behind mining. While equipment dealers make large positive contributions to the agricultural industry in protecting farm employees, they can pose a risk to their own employees’ safety in many ways, including the chemicals they use, the machinery they are around, and the general environment they are exposed to.
OSHA, EPA, and DOT have set forth many regulations that must be followed in order to keep safety, environmental and transportation awareness at the forefront of any employee’s mind. Following is a brief summary of some of these regulations…
Top OSHA Citable Offenses
Following are the items most often cited by OSHA in heavy equipment repair facilities:
- Communication of Safety Regulations – Businesses are required to develop emergency response programs detailing how they would respond to specific events such as fires, chemical spills, natural disasters, chemical exposure and so forth. These emergency plans must include:
- A written program detailing procedures and plans in the event of an emergency. This plan must be accessible to employees and should include an evacuation plan and a place for employees to meet outside the business.
- Employees trained on the emergency response program annually.
- Evacuation maps posted throughout the business with exits, escape routes and meeting place marked.
The reporting of hazardous chemicals remains the most cited OSHA violation at businesses handling large equipment. Several steps must be followed when storing/using hazardous chemicals at a business:
- All information about the chemical and how to properly handle/dispose of it must be written down and available for employees to review.
- Employees must be trained on the written program on an annual basis.
- A safety data sheet (SDS) for each chemical utilized/stored at the business should be filed in a central, easily accessible location in the business.
- A complete inventory of all chemicals in the facility must be updated on a daily basis.
- All containers containing a hazardous chemical must be correctly labeled with the HCS pictogram and the hazards associated with the chemical.
- Powered Industrial Truck Safety – Businesses are required to have a written program in place when operating industrial trucks such as a boom truck. Employees must conduct equipment inspections daily (check tires, forks, functioning horn, etc.) and have written approval from the manufacturer whenever using an attachment for a special/alternative use. Onsite training is also required every three years. Fall protection equipment (guard rail, harness, etc.) is also required when going more than four feet off the ground.
- Respiratory Protection Program – A written program is required for any type of spraying operation (painting, etc.) that requires a respiratory device. In addition, employee training and fit testing is required annually and employees must receive a medical evaluation from their doctor to determine whether or not they can perform the task.
- Confined Space Requirements – A confined space is defined as “limited or restricted means for entry or exit and not designed for continuous occupancy.” Any business with a confined space or some sort of hazard or chance of being trapped must have a permit. This includes a hazardous atmosphere, an engulfment hazard, a chance of being trapped or asphyxiated or any other serious hazard.
In addition, if a technician is working on heavy equipment and cannot be seen (hidden in a combine engine, etc.) the keys must be locked out so the vehicle cannot be started. A Key Lockout Program states in writing what lockout device (combination locks, master lock box, etc.) the business will use to contain the keys and keep the technician safe.
Following are areas where the Environmental Protection Agency (EPA) commonly issues citations during inspections…
Air Conditioning – Any business working on air conditioning (AC) systems in vehicles are required to register all AC machines with the Environmental Protection Agency (EPA). All technicians must be trained and certified in refrigerant recovery and recycling and have their AC cards on file at the business.
Painting – Special rules and regulations apply to businesses painting with a spray gun (not just an aerosol can). The 6H Area Source Rule requires businesses to have a paint booth with a 98 percent efficiency filter document in paint booths utilizing HVLP spray equipment.
Waste Disposal – Businesses are encouraged to do a hazardous waste determination to determine how to properly dispose of waste and to clarify whether an item is hazardous or non-hazardous. Often, the EPA goes through trash during inspections to see if items have been tossed that do not belong such as tires, batteries, used oil, used oil filters, antifreeze, waste paint, paint booth filters, waste solvents and more. If the EPA questions an item found in the trash they will ask the business to prove it has been tested and is okay to discard in the trash. In addition, businesses that have hazardous materials hauled away must document this and keep it on file for three years.
Tier II Reporting – This report must be filed for any bulk chemical stored onsite (10,000+ pounds of any chemical or 500+ pounds of an extremely hazardous chemical) by March 1st every year to three places – the SERC, LEPC and local fire department.
Hazmat Shipping – The driver must have three years of DOT training and a 24-hour emergency response phone number.
Drug & Alcohol Driver Supervisor Training – If a business has drivers hauling materials and driving between state lines, the supervisor must participate in Drug & Alcohol Driver Supervisor training.
Pipeline & Hazardous Materials – Transporting 1,000 or more pounds of hazardous materials requires a placard on the vehicle and the shipment must be registered with the Pipeline & Hazardous Materials Safety Administration (PHMSA). In addition, the driver must carry the DOT’s Emergency Response Guidebook or MSDS with the shipment of hazardous materials and have a 24-hour emergency response phone number.