There are several Occupational Safety and Health Administration (OSHA) inspections in progress at cotton gins right now. We have spent some time discussing OSHA inspections at our local meetings and at the gin schools. There will be additional discussions in January at the Beltwide Cotton Conferences in San Antonio, so be sure and attend the Ginning Conferences this year.
In some ways, the inspections are very similar. We are seeing inspectors that have never been to a cotton gin before, and they make suggestions that are simply not possible to achieve. We are also seeing the normal emphasis in employee training, hazard communication programs and guarding.
One significant difference we are seeing during inspections recently is a tendency to have a safety inspection, followed by a separate health inspection. We don’t know if this is the result of an emphasis in one particular region or something that is being emphasized across the United States.
The safety inspection is the part we have seen in the past. However, during the second inspection, an OSHA hygienist has shown up to measure things like dust levels and noise levels. These are measured by attaching sampling equipment to the employees themselves. As might be expected, most of our employees are not very interested in participating in this type of study, but OSHA does not seem to account for whether the employee actually wants to help or not.
This is another example of being very careful when reviewing OSHA inspections. The OSHA Hearing Conservation Standard does not apply to cotton gins, so it appears OSHA will attempt to use the general duty clause to cite employers for a standard that does not apply. It remains to be seen how any dust readings will work their way into the system. As has been seen in the past, it appears that OSHA continually tries to broaden its regulatory reach during the inspection and citation process.
We have to stay vigilant and not be afraid to speak up when citations are issued that are not properly constructed. These types of citations can be overturned, but you have to follow their protocol and do your homework in order to successfully negotiate a good settlement outcome during any OSHA enforcement action.
Kelley Green of the Texas Cotton Ginners’ Association contributed this article. Contact him at firstname.lastname@example.org.
Don’t Forget To Attend Gin Shows In 2015
Cotton ginners in the Mid-South and Texas should make their plans now to attend two of the biggest ag shows during 2015. The Mid-South Farm and Gin Show is scheduled for Feb. 27-28 at the Cook Convention Center in Memphis, Tenn.
The Memphis event brings together more than 400 exhibitors and is one of the country’s largest indoor farm shows. For more information, contact the Southern Ginners Association office in Memphis at (901) 947-3104.
Meanwhile, the Texas Cotton Ginners’ Association (TCGA) Annual Meeting and Trade Show is set for April 9-10 at the Lubbock Civic Center in Lubbock, Texas. This two-day event also will be the site for the Plains Cotton Growers (PCG) Annual Meeting.
For information about the TCGA meeting, call the organization’s office in Austin, Texas, at (512) 476-8388. For updates on the PCG meeting, call (806) 792-4904.
Nov. 19 – PCCA Board meeting, Lubbock, Texas.
Dec. 2-3 – Boll Weevil Action Comm. – Little Rock, Ark.
Dec. 9-11 – Cotton Board meeting – St. Petersburg, Fla.
Dec. 17 – Staplcotn Board Meeting – Greenwood, Miss.
Jan. 5-7 – BWCC, San Antonio, Texas.
Jan. 14 – PCG Quarterly Meeting, Lubbock, Texas.
Jan. 14-16 – Cotton/Rice Conference, Baton Rouge, La.
Jan. 21-24 – Southern/SE Meeting, Hilton Head, S.C.
Feb. 6-8 – NCC Annual Meeting, Memphis, Tenn.
Feb. 19-20 – USDA Ag Outlook, Washington, D.C.
Feb. 27-28 – Mid-South Farm/Gin Show Memphis, TN.
April 9-10 – TCGA Trade Show, Lubbock, Texas.
May 13-15 – ACSA Meeting, Santa Barbara, Calif.
Aug. 24-26 – NCC Board Meeting, Charleston, S.C.
Sept. 16 – Staplcotn Annual Meeting, Greenwood, MS.
Sept. 16 – PCCA Annual Meeting, Lubbock, Texas.
Oct. 21 – PCCA Board Meeting, Lubbock, Texas.
Nov. 18 – PCCA Board Meeting, Lubbock, Texas.
Dec. 16 – PCCA Board Meeting, Lubbock, Texas.