Gordon Moore of Goodwell, Oklahoma has a consulting firm (Moore Ag Safety) specializing in safety for agriculture. He creates safety plans for feedlots and talks to cattle producers and cowboys, discussing safety and dealing with the Occupational Safety and Health Act, or OSHA, which was created in the 1970s.
“I’ve been in this business more than 15 years, after 21 years in the oil and gas industry. I previously thought agriculture was exempt from OSHA standards, but OSHA has a general duty clause stating that any employer must provide his or her employees a safe workplace,” he says.
“I did more research and found there’s a standard for construction, a standard for general industry and one for agriculture. The standard for agriculture is about 50 pages long compared to 400 to 500 pages for general industry or construction.
Basically, the law says that if there is not a standard to cover a specific instance, you revert back to the general duty clause,” Moore says.
Chuck Pirie, content creation expert for Safety Made Simple (an online training resource company that specializes in agriculture), says beef cattle production has had very few OSHA violations. “From October 2014 through September 2015 (the most recent full year’s report), there were 13 citations in the beef cattle farming and ranching code,” Pirie says.
“Two were for abrasive wheel machinery violations, two for hazard communication (which relates to safety data sheets about chemicals), two for rollover protective structures on tractors, two for guarding of farm equipment (power takeoffs, etc.) and one without a description.
The interesting thing was that four of the 13 were for the general duty clause – which is a catch-all for when there is not a regulation, but there is something hazardous and they cite you for it,” he explains.
“That reflects the fact there are very few regulations in the agriculture section. OSHA may cite regulations from general industry or from the general duty clause – to say something is a hazard that you should have anticipated.
A citation might be given because you recognized the hazard but didn’t do anything to prevent an accident. This is the part that would most often relate to ranchers or farmers – if they have an aggressive bull or are trying to chase down some animals at pasture and take a tumble on an ATV.”
Accidents involving animals are most common
Brady Miller of the Texas Cattle Feeders Association (TCFA) does safety training for feedlot employees. He says most farm/ranch accidents (70 to 75 percent) occur when handling/working with animals because they are unpredictable.
“With cattle producers, it may be horse-related accidents or cattle. In a feedlot, the tank washer might have an animal come up behind him and hit him, or someone might be hit by a gate pushed by an animal or have an accident in the processing barn.
None of these animal-related situations are OSHA-regulated. OSHA personnel have limited knowledge when it comes to animals. But they do have regulations pertaining to the processing barn and excessive sound/noise,” Miller says.
Teaching safety
“We don’t teach safety in terms of satisfying OSHA. People get concerned about what OSHA might require, but I teach safety because it’s part of what a person should do every day. If we keep our guys safe and don’t have accidents, I don’t have to worry about OSHA.
A hard hat is a hard hat whether OSHA requires it or I do it because I don’t want our guys hit in the head. If they are grinding or welding, they need eye protection,” says Miller. It’s just part of the job, but a person is always more OSHA-compliant if people are safe.
“Here at TCFA, we don’t treat OSHA as the most important thing we do. If you say OSHA requires it, everyone gets defensive. But if I say I want them to do this or this because I don’t want your guys to lose an eye, they are on board.
If you mention OSHA to a cowboy, he gets crazy, so you have to put it in different terms,” Miller says. People need to build good safety habits and not have to think about them.
“Once you have employees thinking safety while doing the job (feeding cattle or working on equipment), you start reducing accidents – which is our goal. Most accidents happen around animals, but the most devastating accidents usually involve machinery or the feed mill – which is OSHA-regulated.
Those regulations can apply to everything from machine guarding to lockout/tagout (making sure energy sources are turned off when servicing equipment) to fall protection, equipment training, moving vehicle safety training, PPE (personal protection equipment – which includes eye protection, hard hats, gloves, proper clothing when spraying or dealing with chemicals), etc.,” Miller says.
Pirie is a private consultant for TCFA. “I pull their safety trailer around to whatever member feedyard requests it. I train their people in the OSHA-related training they need. If you are safe, you will be compliant or near compliance anyway. If I approach it this way, I get better results than if I try to teach people to be OSHA-compliant.”
OSHA requirements
“If you have more than 10 employees, you are required to keep OSHA 300 logs,” says Miller. “You need to know what goes on those and what doesn’t. We help people learn how to fill one out.”
Even if you only have a few employees and one gets hurt or killed, you are required to call OSHA. “If you don’t, OSHA can fine you for not calling it in. Another thing many people don’t realize is that someone needs to know CPR and first aid. No matter how good your program is, you are dealing with humans – who make mistakes – and some freak things happen.
Knowing CPR/first aid might save someone’s life. The accident may not involve facility employees; it may be a truck driver there unloading cattle who has a heart attack. You are responsible for his safety, too.
OSHA regulations say CPR/first aid training is required if you are not in close proximity to an emergency facility. In their definition, that means within three to five minutes,” Miller says.
“Every facility should also have job descriptions. On smaller facilities, people will be cross-trained to do multiple jobs. Job descriptions can tell you that if a certain employee will be doing these five things on any given day, you know what PPE that particular employee needs (to be protected) and the training that goes along with it.
“If I have a lot of animal accidents at my facility and put those on my OSHA 300 logs and turn that information in (which not everyone does), and they do a random survey of feedyards and I’m above the national average in number of accidents, this can put me on an OSHA hit list. If they think you’ve had too many accidents during the year, they can inspect you because of your high accident rate,” explains Miller. 
PHOTO 1: A couple of pen riders quietly checking cattle. Photo provided by Gordon Moore.
PHOTO 2: Workers at feedlots and ag facilities should have specific job descriptions and adequate training. Staff photo.
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Heather Smith Thomas
- Freelance Writer
- Salmon, Idaho
Facts about ag injuries
- Agriculture ranks among the most dangerous industries. Between 2003 and 2011, 5,816 agricultural workers died from work-related injuries in the U.S.
- In 2011, 570 agricultural workers died from work-related injuries. The fatality rate for agricultural workers was seven times higher than the fatality rate for all workers in private industry; agricultural workers had a fatality rate of 24.9 deaths per 100,000, while the fatality rate for all workers was 3.5.
- The leading cause of death for farmworkers between 1992 and 2009 was tractor overturns, accounting for more than 90 deaths annually. The most effective way to prevent tractor overturn deaths is the use of roll-over protective structures; however, in 2006, only 59 percent of tractors used on farms in the U.S. were equipped with these devices.
- Every day, about 243 agricultural workers suffer a serious lost-work-time injury. Five percent of these injuries result in permanent impairment.
- In 2011, the injury rate for agricultural workers was more than 40 percent higher than the rate for all workers. Crop production agricultural workers’ injury rates were 5.5 per 100 workers. Animal production agricultural workers’ injury rates were 6.7 per 100 workers. The rate for all workers was 3.8.
- Young workers who live and work on farms are also exposed to potentially dangerous farm-related hazards. Farm operators who hire youth to work on their farm should be aware of all applicable child labor laws.
—Source: OSHA.gov website
Preventing accidents
“The government approach is to help you with safety by prescribing certain do’s and don’ts for work activities,” says Pirie. “Putting together two pieces of material in an assembly line (where you do the same thing over and over) is predictable. By contrast, if you are out in the pasture trying to move animals around, trying to regulate these variables isn’t very realistic.”
“About 18 years ago, after six years of work with feedlots, we saw that most cattle-related accidents occurred when people are not using low-stress handling practices like pressure and release. The opposite of that is hot shots and hollering,” Pirie says. Cattle become excited or scared and may run over someone.
“We started talking about low-stress cattle handling practices and showing how cattle become more predictable when handled quietly, and you can build trust with them. They are not as likely to turn on you or slam into the gate with your hand behind it. There is a correlation between low-stress cattle handling practices and safety.”
