Cotton farming ginners marketplace october 2016

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COTTON

Ginners Marketplace COTTON FARMING IS THE OFFICIAL PUBLICATION OF THE GINNING INDUSTRY.

OSHA Continues Regular Inspections, Presses Regulation Limits In Citation Over the past few years, we have seen a significant number of Occupational Safety and Health Administration inspections in Texas. One reason for the uptick is the much higher number of injuries being reported to OSHA in response to the agency’s new reporting rule. If you are unfamiliar with that rule, refer to the January 2015 edition of the Cotton Ginners Marketplace for a full discussion. This new rule has resulted in a dramatic increase in reporting across the United States. According to OSHA, there were more than 10,000 injuries reported (from all industries) during the first year that the reporting rule was in effect. Prior to this rule, there were only a handful of injuries reported annually. As more injuries are being reported, OSHA is responding with more inspections. The good news is that many of these inspections are done in an expedited manner – using emails, phone calls and faxes. If you are able to satisfactorily answer all of OSHA’s questions using these communications, then, in our experience, the matter is settled without any violations. However, some of the inspections are still done in person, and whenever OSHA inspects in person, you will get a citation.

withdrew the citation. The OSHA area director said that she would have to check with her solicitors to be sure that OSHA had not previously cited a gin under this standard. In other words, if a gin had agreed to a confined space citation in the past, they would not agree to withdraw this citation. Fortunately, there have not been any other citations of this type in Texas.

Consider ‘Expedited Options’ Implications This citation once again brought up how important it is to be sure your violations are valid before agreeing to the penalties. In this particular case, the citation included an

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Cotton Ginners Marketplace

Enlist Help In Checking OSHA Citations In the past, we have discussed the importance of having all OSHA citations reviewed by someone familiar with the agency’s agriculture regulations. In Texas, two gins received citations for violating the noise standard, which does not apply to agriculture. These citations were dismissed after a long battle in the OSHA legal system. This past month, OSHA issued another citation to a gin for failure to have a confined space procedure in place for workers entering the press, module feeder and lint cleaner pits. Again, the confined space standard does not apply to cotton gins. Grain elevators are a different story. If a worker is going into a grain bin, there is a specific OSHA procedure that must be followed beforehand. Fortunately, in this case we were able to meet with OSHA informally and discuss the citation. In the end, OSHA agreed that we were not subject to this rule and

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COTTON FARMING OCTOBER 2016

COTTONFARMING.COM


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