Personal protective equipment hazard assessments

Phil Pitzer is no stranger to the reasons growers give for not using personal protective equipment (PPE). Pitzer, farm safety specialist for the Pennsylvania Department of Agriculture, grew up on a 600-acre fruit farm, then managed it for 23 years after college.

“From the perspective of a person who has lived and worked on a farm the majority of my life, I can tell you that there is a feeling of needing to get the job done in a limited amount of time. Also, in the back of our minds is, ‘This stuff (a certain chemical) isn’t as bad to use as everyone says it is.’ Or, ‘I’m not getting that much exposure.’ There is also a feeling that we become immune to it, that our bodies build up a tolerance over the years,” he says.

(Right)Dale Secher, owner of Carandale Farm in Oregon, Wis., wears a dust mask for protection when working in dusty conditions on his fruit farm. (Left)Secher wears a wide-brimmed hat and other protective clothing when working with any liquid materials head height or higher. Here, Secher looks through his protective gear for the nonporous gloves he will also wear.

“I hear the same thing about hearing loss,” Pitzer continues. “What I hear is, ‘When we get older, we’re going to lose our hearing, anyway.’ Generally, growers do not assess the hazards on their farms to determine if PPE is needed. By the time they reach 75, they may realize that was the problem.”

Whether the issue is chemical protection, eye protection, hearing protection or other PPE, getting busy fruit and vegetable growers to use it on a regular basis can be a tough sell. When it comes to conducting a written PPE hazard assessment to determine the need for employees to use PPE, there’s even less chance that it is being done.

The Occupational Safety and Health Administration (OSHA) requires commercial fruit and vegetable growers, as well as other employers, to conduct written PPE hazard assessments. OSHA also requires that the necessary PPE be made available to employees and that workers be trained in its use. Penalties for violating federal OSHA standards can be costly; they range from up to $7,000 per violation for a “serious” or “other than serious” violation to as much as $70,000 per violation for a “willful” or “repeat” violation.

The basics

At Carandale Farm in Oregon, Wis., Owners Dale and Cindy Secher grow and sell strawberries, fall raspberries, Concord grapes and other fruit on their 40-year-old farm. The Sechers have strong beliefs about sustainable agriculture and use as few chemicals as possible. Nonetheless, Secher has a ready supply of PPE and other protective clothing on hand.

“The best safety equipment you have as a farmer is long pants, heavy pants. You don’t want to farm in shorts,” he says. “I use an apron for mixing and loading for splash protection with anything other than water, such as liquid fertilizers for spot-treatment. A lot of times this comes as a solid and you have to dissolve it in water so it becomes a liquid.” Secher also wears chain saw chaps, eye protection, hearing protection and other PPE when operating a chain saw.

Pitzer’s job includes talking with growers and trying to get them to be safe. He says, however, that it’s often not until a family member or someone that a grower knows is injured on a farm that the importance of using PPE gets through. “These things generally galvanize a community,” he says. “People then start saying, ‘Gee, maybe it can happen to me.’”

Dale Secher of Carandale Farm in Oregon, Wis., has numerous types of personal protective equipment, as well as gloves and other protective clothing that he wears depending on the farm task.

Leading by example is the most important step you can take in getting your employees to use PPE. It’s also critical to look for ways to reduce or eliminate hazards on your farm. If a hazard can’t be eliminated, then PPE needs to be provided. OSHA makes it clear that the agency considers PPE a last line of defense. In other words, if you can greatly reduce or eliminate a hazard by engineering, administrative or other means, that is definitely preferable. Note: Reducing or eliminating an employee’s potential exposure to a hazard does not need to cost a lot of money. Some examples are rotating workers who work around loud machinery or equipment, moving non-noisy tasks away from noisy equipment, or using a less toxic chemical.

The reality is that in the rush to get the work done, most growers don’t take the time to think of ways to reduce workers’ exposure to hazards. “Growers don’t want to hear toxicity rates, breakdowns, how long a certain chemical will stay in your body. They just want something that will do the job today,” Pitzer says.

Assessing your farm

Unless you are a small farm operator and are not subject to OSHA regulations, know that you can be subject to hefty fines if you violate OSHA’s PPE standards. One good resource for more information on those standards is OSHA’s Safety and Health Topics Web page at www.osha.gov/SLTC/index.html search for personal protective equipment (PPE).

Here are some tips on where to begin in conducting a PPE hazard assessment.

  • Identify the potential hazards on your farm—These may include such hazards as tractors and other powered equipment, loud noise, heat and high temperatures, skin rashes (from poisonous plants), dust, sunburn, exposure to chemicals, electrical hazards, sharp objects (including certain hand tools), slip and trip injuries, and others.
  • Write down ways these hazards could be eliminated—If the actual hazard can’t be eliminated, are there ways your employees’ exposure to these hazards can be reduced (short of providing PPE)? For example, can you rotate workers during the hottest parts of the day? Are you willing to retrofit some of your older tractors with rollover protective structures (ROPS)?
  • In cases where the hazards cannot be eliminated, select the appropriate PPE to reduce your workers’ exposure to these hazards—PPE might include anything from dust masks or other respirators to safety goggles, safety glasses, earplugs or earmuffs. Then, provide the appropriate PPE to your employees. Note: Late last year, federal OSHA announced a new final rule that requires employers to provide the vast majority of PPE to employees at no cost to the employee. The only exceptions are ordinary safety-toed footwear, ordinary prescription safety eyewear, logging boots and ordinary clothing and weather-related gear.
  • Make sure the PPE fits each employee and train employees in its use—It’s also important to have your workers demonstrate the ability to properly use the PPE before allowing them to perform the specific task.

As with other OSHA-required rules, be sure you keep a written record of all of the above, including the performance of written PPE hazard assessments.

Barbara Mulhern is a Belleville, Wis.-based agricultural/horticultural freelance writer.