National Farmers Safety Week
By Susen Trail | 09/20/2022
Did You Know That We Are In the Midst of National Farmer Safety Week?
Well, we are and, frankly, no other occupation or employer needs a heightened awareness of the unsafe conditions on the average farm, whether a family farm or an industrial farm. In the 1993, when the Agricultural, 1928, standards were written, there were fewer industrial farms (the really large farms of dairy or grain products) than there are at present. The last change to these standards was in November of 2021, and before that it was in 2011.
If you compare the number of standards specific to Agriculture workplaces to General Industry or Construction you may be surprised at the minimal occupational safety required of Agricultural employers.
1928.1 Purpose and scope. This part contains occupational safety and health standards applicable to agricultural operations.
Subpart B-Applicability of Standards
1928.21 Applicable standards in 29 CFR Part 1910.
1928.21(a) The following standards in part 1910 of this chapter shall apply to agricultural operations:
1928.21(a)Temporary labor camps - § 1910.142; Storage and handling of
1928.21(a)(2) Storage and handling of anhydrous ammonia - § 1910.111 (a) and (b);
1928.21(a)(3) Logging operations - § 1910.266;
1928.21(a)(4) Slow-moving vehicles - § 1910.145;
1928.21(a)(5)Hazard communication - § 1910.1200;
1928.21(a)(6) Cadmium - § 1910.1027.
1928.21(a)(7) Retention of DOT markings, placards and labels - § 1910.1201.
1928.21(a)(8) COVID-19 - § 1910.501, but only with respect to -
1928.21(a)(8)(i) Agricultural establishments where eleven (11) or more employees are engaged on any given day in hand-labor operations in the field; and
1928.21(a)(8)(ii) Agricultural establishments that maintain a temporary labor camp, regardless of how many employees are engaged on any given day in hand-labor operations in the field.
1928.21(b) Except to the extent specified in paragraph (a) of this section, the standards contained in subparts B through T and subpart Z of part 1910 of this title do not apply to agricultural operations.
Subpart C-Roll-Over Protective Structures
1928.51 Roll-over protective structures (ROPS) for tractors used in agricultural operations.
1928.52 Protective frames for wheel-type agricultural tractors - test procedures and performance requirements.
1928.53 Protective enclosures for wheel-type agricultural tractors - test procedures and performance requirements.
APPENDICES TO SUBPART C, 1928 Appendix A and B:
APPENDIX A - Employee Operating Instructions
APPENDIX B - Figures C-1 through C-16
Subpart D-Safety for Agricultural Equipment
1928.57 Guarding of farm field equipment, farmstead equipment, and cotton gins. (Similar to the guarding standards in 1910.)
Subpart I-General Environmental Controls
1928.110 Field Sanitation. (many of the requirements were to be in place no later than 7/30/1987.)
Subpart J-L [Reserved]
Subpart M-Occupational Health
1928.1027 Cadmium (which is a referral to 1910.1027 Cadmium standard.)
If you are thinking that there are very few standards en toto, and even fewer that aren't referred to General Industry standards, then you aren't wrong. Which is odd considering they have the highest fatality rate, 21.5 cases per 100,000 Full Time Equivalent employees, compared to Construction, 10.2 and Transportation and warehousing, 13.4. The most common cause of fatality that comes to mind on a farm is a worker being overcome by gases soon after entry into a silo or silage storage area, soon followed by other farm workers responding without assessing the hazards. This results in a multiplier effect for such a devastating outcome. There are 2.2 million workplaces falling under the definition of Agricultural.
The Agriculture standard states "the standards contained in subparts B through T and subpart Z of part 1910 of this title do not apply to agricultural operations."
This includes safety protocols for:
1910 Subpart D, Walking working surfaces: ladders, scaffolds, and fall protection
1910 Subpart E, Emergency planning: emergency action plans and fire prevention plans
1910 Subpart F, Powered platforms, manlifts, and vehicle mounted work platforms
1910 Subpart G, Environmental Control: noise exposure and nonionizing radiation
1910 Subpart H, Hazardous Materials: compressed gases, storage and handling of liquified petroleum gases and anhydrous ammonia, hazardous waste management
1910 Subpart I, personal protective equipment such as chemical resistant gloves, respirators, steel toed boots, performance of a hazard assessment
1910 Subpart J Permit Required Confined Spaces (such as silos), Lock Out Tag Out, accident prevention signs
1910 Subpart K the requirement to find a medical facility for treatment of injured employees or train someone on site in First Aid, eye wash and shower stations for immediate emergency use
1910 Subpart L, Fire protection
1910 Subpart M, Compressed gas and compressed air equipment
1910 Subpart N, Materials handling and storage, stability of powered industrial trucks
1910 Subpart O, Machinery and machine guarding, mechanical power transmission apparatus
1910 Subpart P, Hand and portable powered tools
1910 Subpart Q, Welding, cutting and brazing
1910 Subpart R, Special industries
1910 Subpart S, Electrical, equipment, installations, hazardous locations
1910 Subpart T, Commercial diving
1910 Subpart U, COVID-19
1910 Subpart V-Y, Reserved
1910 Subpart Z, Toxic and hazardous substances, exposure limits for airborne chemicals, expanded standards for carcinogenic chemicals, bloodborne pathogens and ionizing radiation
Chemical fertilizers have been used on crops since the 1930's and the damage they cause can be long term and cumulative. Chemical hazards from fertilizers include cancer, reproductive effects, nervous system, immune system, and endocrine system effects. Pesticides such as organophosphates, carbamates, and pyrethroids, and fungicides and herbicides all add to an agriculture employee’s skin and respiratory system exposure. Adverse effects from these chemicals include endocrine disruption resulting in hormone disruption, immune suppression, diminished intelligence, reproductive abnormalities and cancer.
As much as we complain about OSHA an over 100% increase in the fatality rate makes it clear that our workplaces are safer when we have a baseline guidance from the standards to go by.
Other adverse health effects are not as final:
- Skin diseases
- Skin and respiratory sensitization
- Hearing loss
- Crushing injuries
- Grain bin fires or explosions
- Animal acquired infections
- Ladders and falls
- Musculoskeletal injuries
- Pesticides and other chemicals
- Respiratory distress
- Unsanitary conditions
- Vehicle hazards
Even though OSHA drops the ball generating enforceable standards it does provide a variety of eTools on their website. As you can see, OSHA acknowledges that there are many more hazards in agricultural workplaces than then are addressed in their standards.
Even if a National Farmer Safety Week only brings awareness it is more than we had last week!