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Yesterday the Georgia Fruit and Vegetable Growers Association held a webinar on heat stress for ag employees. This presentation focused on the requirements of agricultural employers under OSHA’s Heat Stress Emphasis Program. GFVGA was generous enough to share the presentation slides with participants, and we’re including a link to that presentation below.
Our loyal E-News readers will remember a couple of issues back in August and September 2023 that included updates on this issue. For those who may need a refresher, here’s a quick recap of what’s going on with OSHA and heat stress:
Who: Occupational Safety and Health Administration and all agricultural employers
What: OSHA instituted a national emphasis program on heat stress for employees. This means OSHA investigators can visit your farm to conduct an inspection on employee heat stress or can expand an existing visit/inspection to include heat stress for employees.
Where: Everywhere. This is a national program, so OSHA inspectors or state OSHA inspectors (for states that have a state-level OSHA board–Georgia does NOT) in all 50 states.
When: The program has been ongoing since 2022. In late 2023, GMP and other ag groups were made aware that the regional offices for OSHA in Georgia would be conducting more and more random inspections in accordance with this program. You can expect inspections to occur when there are high temperatures in your area (OSHA measures heat using the heat index and considers a heat index greater than 80°F as potentially hazardous).
Why: OSHA has been tracking injuries and fatalities due to heat stroke, heat exhaustion, and other heat related illnesses at work for a few years now. They have determined that 50% of heat-related deaths on the work site happen on an employee’s first day of work and 70% of all heat-related deaths occur within the employee’s first week on the job. OSHA is currently developing rules that will set a national standard for employee safety in high heat conditions, but in the meantime they are conducting inspections to raise awareness and begin cutting down on unsafe working conditions.
Top 10 Things Dairy Farmers Should Know about OSHA’s Heat Stress Emphasis Program:
1. You are included in this program. OSHA is using the North American Industry Codes System (NAICS) to sort out which industries to focus on. Cattle Ranching and Farming (NAICS code 1121) includes dairy farms and stockyards. Also included are vegetable and melon farming, fruit and tree nut farming, and support activities for crop production (NAICS codes 1112, 1113, and 1151, respectively). OSHA has already made one surprise visit on a dairy farm in Georgia.
2. OSHA compliance safety and health officers (inspectors/investigators) are instructed to visit work sites on heat priority days. Heat priority days occur when the heat index is over 80°F. These inspections can be random – the agency has a list of all businesses with the appropriate NAICS codes – or can be done on a referral or complaint basis.
3. OSHA does not measure heat by the recorded temperature alone. OSHA depends on the heat index and a Wet Bulb Globe Temperature (WBGT). When determining whether employers should be implementing heat stress mitigation measures for employees, OSHA will first consult the heat index. When they are onsite and measuring the heat load on your employees they will use the WBGT reading. You can purchase your own WBGT on Amazon and you can download OSHA’s Heat Safety App to track heat index at your exact location.
4. OSHA expects all employers to have a written plan in place to prevent heat-illness and prepare for when/if an employee does contract a heat-related illness.
5. The heat stress plan should include:
- Details on how you are training employees and supervisors on the signs and symptoms of heat-related illness and how to prevent it
- How you will monitor the weather at your farm. You are expected to begin monitoring heat conditions when temperatures exceed 70°F.
- Strategies for how you will prevent heat-illness among your employees
- A plan for how to administer first aid and contact emergency medical services when necessary
6. OSHA recommends these practices for preventing heat-illness
- Scheduled rest breaks
- Unlimited supply of cool drinking water for employees
- Plenty of access to shaded areas to rest and cool down
- Additional rest breaks during peak temperatures
- Implementing a buddy-system so employees can help monitor each other
7. OSHA will expect you to train your employees on your specific heat plan and you should also train on:
- What is heat stress and heat-related illness (environmental, work-related, and personal risk factors)
- How to identify it (symptoms and signs that someone is experiencing heat illness)
- How to prevent it (preventative actions and best practices)
- How to respond if someone shows symptoms (including when to administer first aid and call 9-1-1)
8. OSHA will want you to document that employees have been trained and that they have access to information they need to identify and prevent heat illness. Below are links to several workplace posters in English and Spanish that you should post at your farm.
9. OSHA wants a record of workplace injuries. This relates to both heat-related and non-heat-related injuries. Employers should keep a log of all incidents and have a written report of each individual incident on file. You can use the OSHA 300 form as a logbook of all incidents and you can use the OSHA 301 form to write down details of all incidents. Any time first aid has to be administered, write it down.
10. Finally, these “recommendations” (they aren’t technically the same as other OSHA regulations since OSHA has not finalized its rules and regs on heat stress) were not drafted with your dairy farm in mind. No doubt you are wondering how or why you need to provide additional rest breaks for employees that work in ventilated and shaded milking parlors or ride in air conditioned tractors all day. Employers do have the option of not implementing certain recommendations, but it is very important that you have a written plan that spells out what practices you are employing to prevent heat illness among your employees.
Dairy farms do not fit neatly into these heat stress rules. GMP is working on a draft heat prevention plan to share with dairy farmers that can help in drafting your individual heat prevention plan. As the weather continues to warm up across the Southeast, expect more and more conversations about the heat emphasis program. If you have any questions, please don’t hesitate to contact GMP at bryce@gamilk.org.
GFVGA Heat Stress Presentation
OSHA Heat Illness Prevention Posters
Model Heat Illness Prevention Plan from OSHA
GA Fruit & Vegetable Growers Assoc. Heat Stress Resources Page
OSHA Heat Stress Page
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