First, we have found that gins typically do a good job on the physical front. Things like guarding and electrical compliance are not normally a big problem for our industry. If you are listening to your safety consultants and following up their recommendations, you should be in pretty good shape.
The OSHA inspectors will want to talk to management during an inspection, but they will also want to pull aside some of your employees and visit with them separately. They will be talking to them about how well they are trained, among other things. Ginners typically do a good job of training their workers, but it is often done in an informal manner. This can get you into trouble with OSHA.
It is very important that you document all your training activities, and that you can show that each worker is trained for each job he does. In the eyes of OSHA, if the training is not documented, it did not occur. For example, if you have an employee who works on the press and also operates a forklift, you should be able to show how you trained this worker in both areas.
In our experience, agricultural operations are generally given a fair amount of latitude as to how they train their employees, but it is important that you document what you do so that you can explain it, and show some documentation about how and when the training has occurred. We have seen instances where a worker was hurt in an area, then claimed he was never trained in how to work safely in that area. A sign-in sheet for that training session becomes very important in this scenario.
Policies and procedures are another important aspect of your documentation. You should have these policies and procedures put together in writing, and you should be sure all of your workers receive these items. Most importantly, however, you should be sure that your workers are following the procedures. For example, all gins should have a lockout policy. Go through your policy and be sure it accurately describes how your lockout procedure works. Then make sure your workers are consistently following your practice.
Your gin association should have example training materials and example policies and procedures available for your use. If you find an instance where your practices don’t match the written policy, go over these differences with your association staff or your loss control folks to decide whether you should modify the policy to match your practice or whether it is necessary to modify practices to match the policy. Consistency is the key for staying in compliance.
Finally, if you do get inspected, you may receive a citation. Always have your association staff or council review the citations. As agricultural operations, there are certain standards that are not applicable to cotton gins. Never sign off on a citation without getting it reviewed by someone knowledgeable about OSHA rules and cotton gin operations. There is no downside to having an informal conference to go through the applicability of each citation you receive, and you may save your operation and the entire industry a lot of work by not agreeing to any citation that could have been issued inappropriately.
OSHA inspectors have been pushing the envelope of their own rules in many of the citations we have seen, and it is important that we all work together to be sure they stay within their own laws and regulations when a citation is received by a member of our industry.
Kelley Green, technical services director of the Texas Cotton Ginners’ Association, contributed this article. Contact him at (512) 476-8388 or firstname.lastname@example.org.