Heat Illness – A HOT Topic

Okay… I’ll never be a comedian with that kind of material….

Today OSHA announced its continued targeting of agriculture for its efforts in preventing injuries and illnesses from heat in both indoor and outdoor settings. In the press release linked below, OSHA has said it will be focusing a lot of outreach and enfacement on the agriculture sector and particularly in areas where a high number of H-2A workers are employed.

OSHA has been working on a Heat Injury and Illness Enforcement rule for nearly two years. Last week Acting Labor Secretary told a Congressional committee the agency intends to have a draft rule published later this year. It seems this will be the second summer in a row that OSHA will be inspecting and enforcing heat issues without a proper rulemaking

What does that mean for us as cotton ginners? That’s still a bit unclear. The first Summer OSHA had a focus on heat injury and illnesses the region to our west inspected 13 cotton gins in Mississippi. None of the gins that were visited had full inspections and all had some version of a plan for heat illnesses and injuries. With the increased focus on H-2A it may change the dynamic a bit.

Last fall, OSHA held a Small Business Regulatory Enforcement Advisory (SBREFA) Panel The SBREFA panel included two cotton ginners.. one from Texas and Wes Morgan from North Carolina. Many of the small businesses that participated in the panel said similar things…particularly those in the South. Employers understand heat as we have mostly grown up in it. They take steps to make sure new employees are properly acclimatized and they provide PLENTY of water rest and shade.

At this point (even given all that has been done in the past) our advice is to visit OSHA’s heat illness and injury page and review the materials, post the posters and distribute the handouts to your employees as it begins to get warm this summer. That page can be found here: www.osha.gov/heat

TODAY’S OSHA PRESS RELEASE CAN BE FOUND HERE

Three-Day Safety Seminar Scheduled

We wanted to let everyone know that we’ve scheduled a Three-Day Safety seminar for early August in Tifton. The cost is $300 per person and the sessions are targeted at front line supervisors that will be conducting training and not necessarily managers. If you know you’d like to sign up, here’s the link. If you’d like more detail read on.

SAFETY SEMINAR REGISTRATION

While cotton gins are considered Agriculture in the eyes of OSHA, warehouses are not. OSHA requires all lift truck drivers in cotton warehouses to be properly trained as part their safety program. Prior to the pandemic, the Safety and Insurance committee recommended that we hold Train-the-trainer programs for those members that wanted to have Trainers on staff. We had held a couple of them in 2019 with good success

We contacted the company we’ve been working with on these trainings and worked with them to expand the program. They developed a Three-Day Program that covers several general safety topics and includes the Train-the-Trainer for lift trucks and elevated work platforms.

Since this program was developed relatively recently, we will only hold one such program this year but plan on doing at least one and possibly 2 next year based on participation.

This program is targeted at the front-line supervisors and trainers that have the most influence on the crews. These are the ones conducting the training either formally or on-the-job as most of our ‘training’ tends to be. This is not a purely “rules and regs” but a practical ‘why’ kind of training on many general safety topics but it includes the Train-the-Trainer on lift trucks and powered elevated work platforms. Participants will leave with the knowledge and materials to train their own employees in accordance with OSHA’s regs.

Space is limited to 25 participants. Lunch will be provided for two days. The session will be at the Micro-Gin at the University of Georgia in Tifton August 9-11. The address is in the EventBrite sign-up. Please follow this link above for registration or click here for more details.

DSF

Ladder Safety

I read an article earlier in the week that mentioned it was Ladder Safety Month. This got me to thinking about gins and safety training. Most gins tend to focus on a pre-season safety training once the full crew has arrived to begin the new gin season, but what about the year around employees. When you break it down most gins spend 3-4 months each year ginning cotton, and that tends to be the main focus of safety training. What about the other 8-9 months of the year when the tasks being performed are not directly related to the ginning of cotton, how are you training employees to perform these tasks safely? While this article will focus mainly on ladder safety there will be links provided that cover other topics related to off-season safety.

Statistics show there are around 130,000 injuries and 300 or so deaths each year related to ladders. Ladder usage seems like a simple thing and something we all do on a regular basis, but the question is do we do is correctly and safely. The main points that lead to injuries are improper ladder for the task, damaged ladders, and improper technique.

Ladder Selection:

  • Work environment; hazards like electricity, uneven surfaces, or obstructions can affect the choose of ladder to be used.
  • Work length required; never stand on the top cap on a step ladder or use the top 3 rungs on and extension ladder.
  • Duty rating; This is the total amount of weight the ladder will support. This includes the worker and any tools or materials that the ladder will be supporting.

Ladder Inspection:

  • Are all parts of the ladder in good working condition? Look for broken or damaged rungs, rails, feet, and/or braces.
  • Is the ladder clean? Look for grease, oil, or other debris that could make the rungs slippery.
  • Confirm the area the ladder will be placed is level, sturdy, and free from hazards.

Ladder Use:

  • Be aware of what you are doing and the area around you.
  • Maintain 3 points of contact with the ladder at all times. Use a towline, tool belt, or helper to convey tools and materials.
  • Climb slowly and deliberately while always facing the ladder.
  • Keep your body centered between the rails at all times. Never overreach or lean to the sides while working from a ladder.
  • Never attempt to move a ladder while standing on it.

I cannot cover all aspects of ladder safety in this article, but did cover some of the most important. Please take a look at some of the links provided to get additional information concerning ladder safety.

OSHA Fact Sheet for extension ladders:

OSHA Fact sheet for Step ladders:

Although this article focuses on ladder safety, take this opportunity of consider other tasks that are being performed in the off-season and make sure you are training your employees to perform these tasks safely. There are several short training lessons covering a wide range of topics provided in chapter 5 of your Safety Reference Manual. If you would like additional information or have questions please contact me at andy@southern-southeastern.org.

Electronic Submission of OSHA 300A Information

As we approach the end of February, I would like to remind our members of the approaching deadline to electronically submit injury and illness data for the 2021 calendar year. The OSHA Record Keeping Rule requires employers keep records of all work related injuries and illnesses. This includes the OSHA 300, 300A and 301 forms that employers must have on file. In addition to the forms list above, there is an additional requirement to electronically submit injury and illness data on OSHA’s ITA website.

Any employer in certain NAICS codes (INCLUDING GINS) with 20 or more employees at any time during the calendar year are required to enter this data electronically. The data entered electronically is essentially the same data contained in the OSHA 300A form. The deadline for electronic submission is March 2, 2022. After the March 2, 2022 deadline date the submission process is (or should be) locked and no data can be submitted at that point. Please do this prior to the deadline.

To access the electronic submission portal simply click this link OSHA Electronic Submission Page . Once you have accessed the OSHA ITA web portal via the above link, there will be a red tab on the right side “Launch the Injury Tracking Application” that will bring up the page to log into your account. Once logged in you will be prompted to enter data from the 2021 calendar year. Even if you had no entries on your OSHA 300A form you must still electronically submit this data on the OSHA ITA website.

If this is your first time using this electronic submission application or you just need help, there are several FAQ items that may help. There is also a blue tab on the right side “Job Aids (how-to documentation)” that provides step by step guidance. Feel free to contact the association as well if we can be of assistance.

Hopefully, this article will serve as a reminder of what must be reported and posted to be in compliance with OSHA’s Recordkeeping Standard. If OSHA comes to your facility, they will ask to see these forms going back for a period of 5 years. It is important to have the files and data on hand and easily accessible. More information regarding OSHA Recordkeeping can be accessed through OSHA Recordkeeping Rule as well as the 2020 Southeastern Cotton Ginners Safety Reference Manual.

OSHA 300A Form Posting Deadline Approaching

As we approach the end of January, I would like to remind our members that the OSHA 300A Form posting deadline is approaching.  The OSHA Record Keeping Rule requires employers keep records of all work related injuries and illnesses.  This includes the OSHA 300, 300A and 301 forms that employers must have on file.  If you do not already have a copy of this form it can be accessed through this link OSHA Recordkeeping Forms and Instructions.  The 300A Summary of Injuries and Illnesses is the only form that must be posted from Feb. 1 to April 30 of each year.  The 300A must be posted in a common area where notices to employees would normally be posted. Be sure to post this form beginning February 1, 2022.

 It is very important that the OSHA 300A Summary be filled out completely and correctly.  In the case that there were no work-related accidents to report, the form must be filled out with zeros in each blank.  Often the establishment information is also overlooked and or just not signed.  One area of the establishment information that creates some confusion is the area asking about average number of employees and total hours worked.  The average number of employees is simply the total number of paychecks written divided by the number of pay periods.  This should include all full-time, part-time, temporary, migrant, salaried, and hourly employees.  

The other form found at the link above is the OSHA 300 Log of Work-Related Injuries and Illnesses.  This is a log containing information about every work-related death and almost every work-related injury or illness that involves loss of consciousness, restricted work activity or job transfer, days away from work, and/or medical treatment beyond first aid. You must consider an injury or illness to be work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness.  It is also important to completely fill out the OSHA 300 form. All columns must be totaled even if you had no accident to reports there must be a zero for a total.  The information from the OSHA 300 form is used to complete the OSHA 300A form.

This is also a good time to enter your 2021 injury and illness data on the OSHA Web Portal.  Any employer with 20 or more employees at any time during the calendar year is required to enter this data electronically.  The data entered electronically is essentially the same data contained in the OSHA 300A form.  The deadline for electronic submission is March 2, 2022.  To access the electronic submission portal simply click this link OSHA Electronic Submission Page

 Hopefully, this article will serve as a reminder of what must be reported and posted to be in compliance with OSHA’s Recordkeeping Standard.  If OSHA comes to your facility, they will ask to see these forms going back for a period of 5 years.  It is important to have the files and data on hand and easily accessible.  More information regarding OSHA Recordkeeping can be accessed through OSHA Recordkeeping Rule as well as the 2020 Southeastern Cotton Ginners Safety Reference Manual. 

OSHA’s Vaccine Mandate Moving Forward

Late Friday afternoon a three judge panel in the Sixth Circuit lifted the stay on the Biden Administration’s Emergency Temporary Standard (ETS). The ETS has a number of ongoing law suits and a Federal appeals court placed a stay on the rule before it even got going. Now the Sixth Circuit has lifted that stay and the rule may proceed.

For review, this vaccine mandate only applies to employers with 100 or more employees company wide. OSHA has said it will use it’s enforcement discretion for this rule. OSHA will begin enforcing the rule on January 10 with a February 9 deadline for the vaccine or test requirements.

More will follow after we have a chance to digest this ruling. This is likely not the end of this and we will continue to see how this unfolds. If you have or have had more than 100 employees since November 5 (original date of rule) you will need to move forward with your compliance activities.

More to come

DSF