OSHA has paid visits to two gins in Texas over the last 12 months. We have learned several lessons from these two visits. One of the main lessons we have learned is that the ginning industry has very good safety programs, policies and procedures in place. If you are following all the recommendations and procedures outlined by your regional and national associations, you are already in a pretty good position.
There are a few things OSHA will always look for during an inspection. The biggest from our standpoint is the Hazard Communication (HazCom) program. If you do not have a HazCom program, you need to put one together. These programs are not complicated, and they have been a part of Association safety programs for many years. If you have one in place, go back through it and be sure it is up to date. A new formatting system for the Safety Data Sheets was put into place last year, so all HazCom programs will need to be updated to include new sheets.
Be sure your workers are trained on the system. If OSHA comes to visit, there is a very high probability that they will want to see this program. Another item OSHA seems to be focusing on this year relates to forklift operation. Having a good program for each of your workers is important, and that includes forklift operators.
As a final note, if you find yourself subject to an OSHA inspection, remember a few key points. The first is that you must treat the OSHA inspector respectfully, but carefully. Show them what they request to see, but don’t offer more than they ask. For example, if they ask to see your press, take them into the gin through the door as close as possible to the press. In addition, if they ask to do something you would not allow a worker to do, such as access a restricted area, explain to them that it is against your policy to go there.
Finally, when the citation is finally issued, be sure to let your association folks review the citation. The cotton ginning industry has a good story to tell when it comes to worker safety. It is important that this story be communicated, even during an OSHA inspection.
Kelley Green of the Texas Cotton Ginners’ Association contributed this article. Contact him at email@example.com or (512) 476-8388.