A lot of concern has been raised about the Agricultural relief program that was announced late last week. There are not many details about the program available but rest assured your organizations are positioned to work with USDA when opportunities arise. Please see the article below directly from this weeks Cotton’s Week from the National Cotton Council.

Broad-Based Producer Assistance Outlined 

Late on April 17 Agriculture Secretary Sonny Perdue announced during the White House coronavirus briefing the general parameters of USDA’s initial relief to producers suffering losses from the COVID-19 impacts. The $19 billion package includes $3 billion in food purchases for donation to food banks and other feeding programs. These purchases will consist primarily of fruits and vegetables, dairy products, and meat products. The remaining $16 billion will be used for direct payments to producers of row crops, specialty crops, dairy and livestock. The overall funding allocation among these categories is not finalized, but the initial indication is approximately $4 billion for row crops, including cotton. 

For a commodity to qualify for support it must have suffered at least a 5% price decline between January 1 and mid-April of 2020. At this time, it is the NCC’s understanding that the payments will be determined based on two calculations: 1) 85% of the price decline between January 1 and mid-April and 2) 30% of the projected price decline through the next two quarters of 2020. Production eligible for support will be determined based on the quantity of the commodity that is still “at risk” as of January 1. At this time, determining payments to a producer is not possible given the lack of available details for the relevant prices and eligible quantities. USDA also announced a payment limit of $125,000 per commodity will apply with a total, overall maximum payment limit per person or entity of $250,000 if the farm has multiple commodities that qualify for payment. There also is an adjusted gross income test. 

The NCC is in regular communication with Congressional offices and the Administration about the remaining details and unanswered questions from USDA’s announcement. 

USDA is in the process of developing the regulation to implement the program and then must get the regulation approved by the White House Office of Management and Budget. USDA plans to begin the signup process sometime in May with the goal of issuing payments beginning in late May or June. 

The expectation is that USDA will utilize the $14 billion in additional Commodity Credit Corporation funding available in July for additional assistance. The NCC already is working with Congress on what needs to be included for multiple U.S. cotton industry segments in the next round of relief provided by Congress and the Administration.

Over the past few weeks we have not given a lot of space to OSHA and the impact of the Coronavirus in the OSHA world. I don’t plan on outlining all of the various documents OSHA has put out in the past few weeks. Suffice it to say they are not sitting around.

There are a couple main points that you probably need to take away. First, OSHA will be using enforcement discretion when it comes to violations impacted by the COVID emergency. An example of this may be where you tried to get your lift truck drivers re-certified and use an outside vendor to do this. You may not be allowing outside vendors or those vendors may not be going onsite anywhere. These kind of violations will be appropriately handled as long as the employer makes a good faith effort to comply. ONLY violations that do not put the employees in danger of death or serious harm will be handled with enforcement discretion and then only when the employer makes good faith efforts to comply but could not because of the Coronavirus emergency.

The next thing is that OSHA is not making as many on-site inspections. Cases such as fatal accidents and coronavirus related complaints will draw an on-site inspection but most will be handled in other ways or delayed until after the emergency has passed. When OSHA has to go on-site it has issued guidance to its employees on ppe and best practices when they do go out in the field.

Finally, if a complaint is made regarding COVID-19, OSHA is considering whether the employer is using best practices and following CDC and department of health guidance with their employees. If an employer is not following good practices to mitigate the virus, it is possible for OSHA to write up a General Duty Clause citation. So do your best and don’t let your guard down.

OSHA’s full Coronavirus page can be found here.

As agriculture we and our employees are considered critical infrastructure. As the virus makes its way through the population, whether locked down or not, some of our employees will inevitably be exposed to someone (family member, close friend etc.) that has the virus. Being critical infrastructure, and staying working during the healthcare emergency, losing employees is not a great option but exposing your other employees to the virus isn’t a good option either.

We’ve seen what can happen in an environment such as a meat packing plant employees start to share the virus. No one wants a cotton gin to be the next hotspot of Covid-19.

The CDC has developed guidance to help critical infrastructure workers and employers deal with this situation…a situation you will have to deal with at some point. Please refer to the link below. Also download THIS DOCUMENT which is a PDF of some of the same information on how to handle these asymptomatic people.

CDC GUIDANCE ON CRITICAL INFRASTRUCTURE EMPLOYEES

In addition to CDC guidance for critical infrastructure, the Georgia Department of Agriculture (there are likely other sources as well) has developed a poster/guidance for employers where workers are housed in semi-communal setting such as H-2A or other migrant worker housing. Some other states are considering regulatory approach to such situations.

Please download and review the document from the Georgia Department of Ag HERE… Spanish here

The National Cotton Ginners Association has announced the cancellation of all three of the gin schools for 2020. The difficult decision came amid uncertain travel availability for instructors and organizers. Travel combined with uncertain rules in each venue made the cancellation inevitable Even if stay-at-home restrictions have been relaxed the federal phase-in protocols are going to limit gathering size etc. making it difficult to plan and conduct a school.

Harrison Ashley with the National Cotton Ginners has indicated that even though the decision was a very tough one, the NCGA is committed to the program and that they plan on bigger and better schools next year.

More information on the cancellation will be sent out in cotton’s E-News and Cotton’s Week via the National Cotton Council site.

DSF

We have just a handful of responses but I wanted to share the things our members are doing to help protect their employees and others during this Coronavirus Emergency. BTW according to the responses so far, gins in the SE have donated over 8,000 masks to help combat the spread in medical facilities. WAY TO GO!!!!

To help stop the spread from the outside world

• Office has been closed. Office employees only allowed in office.
• We have locked the doors to the office. Truck drivers call when they get to the door. We take all of their info over the phone. We unlocked the door, and we have an 8ft table separating us. We pass one sheet over for driver to sign for our copy. We’ve shut down outside vendors as well. Only outside folks that can come in or are supposed to come in at this point are truck drivers.
• Employees only no contact with drivers including paperwork.
• Doors are locked. Only employees allowed in the facilities unless there is prior approval. Drivers must check in at scale ticket window and do not touch any paperwork that we keep and warehouse crew is alerted as to which truck is getting what load. Window area is lysoled after every driver and hand sanitizer is used.
• Office limited to employees only doors locked split in two crews come in alternate days all truck drivers are dealt with through window all employees are working separately.
• We have stopped interacting with truck drivers. They have to call into the office to check in and we fill out their paperwork for them and leave them a copy outside the door. We then tell the warehouse staff which load to put on the truck without them having to have contact with the truckers.
• Office is locked to the public. Shipping of cotton and seed continues. Cotton – driver calls the office, we fill out his shipping order; make copies and put in mailbox at front door for driver to get or WH mgr takes to him. Driver remains in truck during his visit. Seed – seed truck drivers pull on the scale, call us with load number and other required information; we weigh them in, they get their load, we complete their paperwork (no signature was OK’d by Chickasha) and put in mailbox at front door. Any other business is by appt only.
• We are not allowing truck drivers inside the office. I meet them outside to sign papers and tell them where to go to be loaded.
• We have stopped truckers from coming in the office. We deal with them through a service window and via a speaker that is designed to talk to module truck drivers during the season. We have stopped all salesman from coming into the office. We have designed specific tasks for all personnel so that they maintain distance between them. We’ve subdivided the warehouse and assigned personnel their own forklift and area to pull from so they don’t break social distances.
• Stopped all traffic into office. Truckers, salesman, delivery drivers, are met outside and paperwork handled at picnic table.
• Closed except for truck drivers. Ask that drivers remain in the truck except for opening & closing of doors. paperwork transfer only goes one direction.
• Closed the office to employees only. Limit contact with truck drivers through window at scales.
• Office doors are locked. All interaction with truck drivers is through the door. Vendors are met outside, none showing up now though.
• Changed the way we interact with truck drivers that pick up cotton. No vendors or sales people on site.
• We have locked the office and allow no one in. Truck drivers call the office number, that we have posted on our door, to give the pertinent pickup information. Paperwork is handled by cracking a sliding window in the office.
• Only open to truck drivers or by appointment
• No drivers inside office. All paperwork filled outside. Only employees allowed in the office. locked the doors and pass paperwork to drivers through the window

To Help Stop the Spread Between Employees

• Social Distancing guidelines that the state has put in to place. 6′ apart wash hands 20 Secs
• We have discussed the virus and importance of social distancing. Warehouse employees are already separated for most part. We have kept our distance within the office. Gin employees are the toughest at this point. We are trying social distancing best we can. But the key team in the gin is still in there making repairs and working. We’ve also stressed the importance of social distancing and avoiding crowds once they leave work and go home.
• Skeleton crew and implementation of no contact policy.
• Made sure employees have plenty of hand soap at all washing stations.
• Alternate work days and separate working areas
• They have been told to wash their hands frequently and stay apart 6 feet or more if around each other but the majority of our workers are spaced out into different warehouses and are not around each other.
• Hand sanitizer, soaps, wipes, masks, etc are provided as we have them 1. Office closed to public. Surfaces are wiped down several times per day. 2. WH employees are not within close proximity of each other pulling loads. They have been instructed to wipe down FL and wash hands often. 3. Only two employees in gin working on breakdown. All is working well as long as we can get the supplies we need. Waiting on smaller personal bottles to put hand sanitizer in.
• Frequent Handwashing & frequent disinfecting door knobs etc.
• Trying to stay 6’ apart. Encouraging regular hand washing and disinfecting door knobs as often as possible.
• Split crew into bale warehouse and gin crew. Warehouse crew reports directly to the warehouse and has no contact with the gin other than by phone. No issues so far.
• Split workers into 2 groups alternating days.
• No area with more than 6 employees. All employees to maintain distance between themselves. If any signs of any illness, the employee is not allowed to come to work. Frequent hand washing is required and sanitizer is located conveniently for all employees.
• Eliminated the interaction between employee’s. frequent sanitation of each area. setting up a separate break area and restrooms for each employee. All are working well
• We are not allowing people to gather in the break room. Frequent hand washing is being encouraged. Warehouse people are separated anyway on their forklifts. The gin crew is working separated as much as possible. Daily checks and reinforcement of the facts concerning the need to social distance and not to be around other people when they are off the job is done by the gin manager. He encourages everyone to do their part.
• We are on a skeleton crew right now anyway. We are limiting contact between employees and letting them work in different areas.
• Split shifts, working from home.
• social distancing

Just a quick note to let you all know that the SBA has issued some new rules on the PPP program. These are interim final rules but not final final rules. All this means is that it is subject to change. One take-away is that the interest rate which was 1/2% is now 1% and in the law allowed up to 4% but SBA has kept it at 1 for now.

The best summary I could find for the rules as of yesterday is found here:

https://www.franczek.com/blog/sba-issues-interim-final-rules-and-additional-guidance-regarding-paycheck-protection-program/?utm_source=elinfonet

I hope this helps.

DSF