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COTTON FARMING IS THE OFFICIAL PUBLICATION OF THE GINNING INDUSTRY.
Gins Should Prepare For OSHA Visits 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.
18 COTTON FARMING
DECEMBER 2014
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Module Mover Chain
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