COTTON
Ginners Marketplace COTTON FARMING IS THE OFFICIAL PUBLICATION OF THE GINNING INDUSTRY.
Be Prepared When OSHA Visits Your Gin
late 3/7/14 3:26 PM Page 1
We have seen quite a few OSHA inspections occurring in the cotton ginning industry lately. If you have never been through one, there are a few things you can do now to make it go much more smoothly. 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,
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