Cal/OSHA

Cal/OSHA Safety and Health Requirements

The California Occupational Safety and Health Act protects California employees from workplace hazards. The Act is enforced by the Division of Occupational Safety and Health within the Department of Industrial Relations. (Citations to GISO sections are to General Industry Safety Orders, which are in title 8 of the California Code of Regulations.)

Cal/OSHA Consultation Service: Cal/OSHA offers a consultation service that helps employers voluntarily comply with the extensive employee safety-and-health standards. Offered at no cost to employers, the Consultation Service can be of particular help to small employers without the resources to keep pace with those standards. The Consultation Service is separate from Cal/OSHA's Compliance Unit. At the employer's request a Cal/OSHA consultant will make an onsite visit and help the employer identify any existing violation. Cal/OSHA consultants do not cite employers for safety-and-health violations. Instead, they advise how to correct the condition. The consultant and employer try to agree to a reasonable abatement plan. However, if the employer refuses to abate an imminent hazard or serious violation, the Cal/OSHA Compliance Unit would be notified.

Injury and Illness Reporting: An employer must file with the Division of Labor Statistics and Research or its workers' compensation insurer a report of every occupational injury or illness that results in lost-time beyond the date of injury or illness, or that requires medical treatment beyond first aid. This report must be filed within five days after the employer learns of the injury or illness. A death or serious injury or illness (requiring hospitalization for more than 24 hours other than for purposes of observation) must be reported to the Division of Occupational Safety and Health by telephone or telegraph within 8 hours after the employer knows or should have known of the death or illness.

Employers must also maintain in each establishment a log of all recordable occupational injuries and illnesses for that establishment.

Injury and Illness Prevention Program: Every employer in California must establish, implement and maintain an effective written injury and illness prevention program (IIPP). Because of the importance of this requirement, a whole section is devoted to the subject. See the next section starting on page 14.

Field Sanitation: Agricultural employers must provide toilet and handwashing facilities and drinking water where one or more employees are performing hand-labor operations. "Agricultural employer" includes a person or entity that:

1. Owns or operates an agricultural establishment;

2. Buys a crop before it is produced and exercises substantial control over production (e.g., a packinghouse); or

3. Recruits and supervises employees (e.g., a farm labor contractor) or manages an agricultural establishment (e.g., a grove or vineyard manager).

A farm labor contractor is generally liable for failing to provide field sanitation facilities to the farm labor contractor's employees.

Definitions: A "hand-labor operation" is one performed by hand or with a hand tool in producing an agricultural commodity. Some examples of "hand-labor operations" are: the moving of irrigation pipes and other irrigation equipment by hand; the hand-cultivation, hand-weeding, hand-planting and hand-harvesting of crops; and the hand-packing of produce into containers, whether done on the ground, on a moving machine, or in a temporary packing shed located in the field.

"Hand-labor operations" do not include logging operations, the care or feeding of livestock, or hand-labor operations in permanent structures (e.g., canning facilities or packing houses).

Alternative Compliance: An agricultural employer may meet the field sanitation facility requirements specified below by providing transportation to the facilities only where at least one of these three conditions applies:

1. Employees are performing field work for less than two hours (including transportation time to and from the field);

2. Fewer than five employees are engaged in hand-labor operations on any given day; or

3. Employees are not engaged in hand-labor operations.

Agricultural operations not involving hand-labor must comply with Title 8, Calif. Code of Regs., §§3360-3368 (sanitation facilities in permanent places of employment).

Drinking Water Requirements: Potable drinking water must be provided during working hours at locations readily accessible to all employees. Access to the water must always be permitted.

The water must be fresh, pure, cool, and in sufficient amounts to meet the needs of all employees.

Drinking water containers must be constructed of materials that maintain water quality. They must have a faucet, fountain, or other device to draw the water.

The water must be dispensed in single-use drinking cups or by fountains. "Common-use" (i.e., shared) cups or dippers are not permitted unless they are cleaned and sterilized between uses.

Toilet and Handwashing Facilities: A fixed or portable facility designed to collect and contain the products of both defecation and urination must be provided. It must be supplied with toilet paper adequate to employee needs. It may be a biological, chemical, flush or combustion toilet or sanitary privy.

Separate toilet facilities for each sex must be provided for each 20 employees or fraction thereof. One handwashing facility must be provided for each 20 employees or fraction thereof. When fewer than five employees are working, separate toilet rooms for each sex are not required, as long as toilet rooms can be locked from the inside and contain at least one water closet.

Urinals may be installed instead of water closets in toilet rooms to be used only by men, as long as the number of water closets is at least two-thirds the minimum number of toilet facilities.

Toilet and handwashing facilities must meet these standards:

1. Toilet facilities must be screened.

2. Toilet and handwashing facilities must be ventilated and have self-closing doors, lockable from the inside, and otherwise be constructed to ensure privacy.

3. Toilet facilities must have an area of at least 8 square feet, with a minimum width of 2½ feet for each toilet seat. A facility must have a minimum area of 10 square feet, with a minimum width of 2½ feet, when a urinal is included. Sufficient additional space must be included if handwashing facilities are within the facility.

4. The waste water tank on chemical toilets must be constructed of durable, easily-cleanable material and be able to hold at least 40 gallons. It must be constructed to prevent splashing on the occupant, field, or road.

5. The handwashing water tank must be able to hold at least 15 gallons.

6. Units housing toilet and handwashing facilities must be rigidly constructed. Their inside surfaces must be of nonabsorbent material, smooth, readily cleanable, and finished in a light color.

7. Water flush toilets and handwashing facilities must conform to Title 24, Calif. Code of Regs., Part 5, Calif. Plumbing Code.

Location: Toilet and handwashing facilities must be accessibly located near each other. They must be within a ¼-mile walk or five minutes of employees, whichever is less. Where due to terrain it is not feasible to locate facilities as required above, they must be located at the point closest to vehicular access.

Maintenance Standards: The employer must service and maintain potable drinking water, toilet and handwashing facilities in accordance with appropriate public health sanitation practices, including the following:

Drinking water containers must be regularly cleaned, refilled daily or more often as necessary, and covered and protected to prevent persons from dipping the water by hand or otherwise contaminating it.

Toilet facilities must always be operational, clean, sanitary, and in good repair. Written records of service and maintenance must be kept for at least two years.

Toilet paper must be provided in a suitable holder in each toilet unit.

Effective odor control and solid-liquefying chemicals must be used in chemical toilet waste holding tanks.

Contents of chemical tanks must be disposed of by draining or pumping into a sanitary sewer, an approved septic tank of sufficient capacity to handle the wastes, a suitably sized and constructed holding tank approved by the local health department, or by any other method approved by the local health department.

Privies must be moved to a new site or taken out of service when the pit is filled to within 2 feet of the adjacent ground surface. The pit contents must be covered with at least 2 feet of well-compacted dirt when the privy is removed.

Handwashing facilities must meet these standards:

1. Pure, wholesome, and potable water must be available for handwashing.

2. Handwashing facilities must be refilled with potable water as necessary.

3. Soap or other suitable cleansing agent and single-use towels must be provided.

4. Signs stating that the water is only for handwashing must be posted.

5. Handwashing facilities must be provided at or near the toilet unit.

6. Handwashing facilities must be clean and sanitary.

Notice to Employees: The employer must notify each employee of the location of the sanitation facilities and potable water and allow each employee reasonable opportunities during the workday to use them. The employer must ensure that employees use the sanitation facilities and inform each employee of the importance of these good hygiene practices to minimize exposure to the hazards in the field of heat, communicable diseases, retention of urine, and agrichemical residues:

1. Use the water and facilities provided for drinking, handwashing, and elimination;

2. Drink water frequently, especially on hot days;

3. Urinate as frequently as necessary;

4. Wash hands both before and after using the toilet; and

5. Wash hands before eating and smoking.

Required Reports: An employer cited under this section must provide to Cal/OSHA annually for a period of five years after the final order on a citation a declaration giving this information: the estimated peak number of employees; the toilet, handwashing, and drinking water facilities to be provided; and any rental and maintenance agreement related to these requirements.

Recordkeeping: All employers, except those with no more than 10 employees at any time during the prior year, must keep Cal/OSHA records.

These records must be kept on a calendar-year basis and retained for at least five years:

1. A Cal/OSHA Form 301, Injury and Illness Incident Report (replaces Form 101, Supplementary Record of Occupational Injuries and Illnesses) completed on every injury or illness requiring medical treatment but not mere first aid. Labor Code section 5041 defines "first aid" as any one-time treatment of minor scratches, cuts, burns, splinters, or other minor industrial injury. As such, first aid does not require the employer to record the injury, nor does it trigger the need for an Employee Claim form or Employer's First Report form.

If a physician or other medical technician renders first aid and later performs a follow-up observation of it, the injury is still considered to be within the first-aid exception.

But if the second visit results in further treatment, then the injury must be recorded.

2. Cal/OSHA Form 300, Log of Work - Related Injuries and Illnesses, is completed from Form 301. Cal/OSHA Form 300A Summary of Work - Related Injuries and Illnesses (replaces Form 200, Log and Summary of Occupational Injuries and Illnesses) must be posted in a conspicuous place in the workplace during the months of February through April every year. Employers who employed ten or fewer employees at all times during the last calendar year, do not need to keep or post Cal/OSHA injury and illness records.

In addition to keeping records of occupational injuries and illnesses, an employer must allow employees or their representatives access to the employer's log of occupational injuries and illnesses and to accurate records of employee exposure to potentially toxic substances or harmful physical agents.

GISO section 3203 requires employers to maintain records that document compliance with that regulation's requirements to maintain an effective written injury and illness prevention program. Employers with fewer than 10 employees are exempt from certain record requirements. Here is a summary of the recordkeeping requirements in section 3203(b):

Records of the steps taken to implement and maintain the program include:

1. Records of scheduled and periodic inspections required by subsection (a)(4) to identify unsafe conditions and work practices, including person(s) conducting the inspection, the unsafe conditions and work practices that have been identified and action taken to correct the identified unsafe conditions and work practices. These records must be maintained for three years.

Exception: Employers with fewer than 10 employees may elect to maintain the inspection records only until the hazard is corrected.

2 Documentation of safety and health training required by subsection (a)(7) for each employee, including employee name or other identifier, training dates, type(s) of training, and training providers. These must be maintained for three years.

Exception No. 1: Employers with fewer than 10 employees can substantially comply with the documentation provision by maintaining a log of instructions provided to the employee with respect to the hazards unique to the employee's job assignment when first hired or assigned new duties.

Exception No. 2: Training records of employees who have worked for less than one year for the employer need not be retained beyond the term of employment if they are provided to the employee upon termination of employment.

Weeding, Thinning and Hot-Capping (GISO section 3456): Employees may not use tools to weed, thin or hot-cap in a stooped, kneeling or squatting position, and they may not engage in unnecessary hand weeding, hand thinning and hand hot-capping in those positions. Specifically:

1. Employees may not weed, thin or hot-cap in a stooped, kneeling or squatting position using either:

a. Short-handled tools (i.e., ones with handles less than 48 inches long) or

b. Long-handled tools (i.e., ones with handles at least 48 inches long).

2. Employees may not hand weed, hand thin or hand hot-cap in a stooped, kneeling or squatting position unless at least one of the following applies:

a. The employer can show that doing the task by hand is necessary because there is no readily available reasonable alternative means (e.g., a long-handled tool) suitable and appropriate to the production of the commodity (i.e., presumably, so the task could be done while standing).

b. Hand weeding, hand thinning and hand hot-capping is only occasional or intermittent and incidental to a non-hand weeding operation; this includes both non-weeding operations (e.g., irrigating or harvesting) and weeding operations where employees are generally standing while using long-handled tools. To be "occasional or intermittent," the time devoted to doing the task by hand must be limited to 20% of an employee's weekly work time.

c. The commodity plants being weeded, thinned or hot-capped:

i. were spaced less than 2 inches apart when planted;

ii. are growing in a field or greenhouse registered as organic with the county Agricultural Commissioner;

iii. are seedlings; or

iv. are horticultural plants growing in tubs or planter containers with openings of 15 inches or less.

3. Employees engaged in hand weeding, hand thinning or hand hot-capping that is not occasional or intermittent get another 5 minutes on top of the 10-minute rest period they are allowed by law for every 4 hours worked or major fraction thereof (i.e., their rest-break time is 15 minutes instead of 10 minutes).

4. Employees engaged in hand weeding, hand thinning or hand hot-capping must be supplied with gloves and kneepads as may be necessary and with training in accordance with existing Injury and Illness Protection Program guidelines.

Heat-Illness Prevention (GISO section 3395): Employers must provide outdoor employees with drinking water, access to shade, and heat-illness training.

Drinking Water: Where the supply of water is not plumbed or otherwise continuously supplied, an employer must either have on hand one quart of drinking water per hour per employee at the start of a shift or show that procedures were in place to replenish the water supply to enable each employee to drink that much water. Further, an employer must stress the importance of frequent water consumption.

Shade: An employer must provide employees suffering from heat illness or who believe they need time to recover from heat exposure to prevent the onset of heat illness with access to cooling shade for at least five minutes. Except for employers in the agriculture industry, cooling measures other than shade (e.g., use of misting machines) may be provided in lieu of shade if the employer can demonstrate that these measures are at least as effective as shade in allowing employees to cool.

Training: Employers must educate covered employees and their supervisors on ways to avoid heat illness and steps to take if it nonetheless occurs. Employers must train all outdoor employees in:

1. The environmental risk factors for heat illness

2. The personal risk factors for heat illness

3. The importance of:

a. Frequently drinking small amounts of water

b. Acclimatization

c. Immediately reporting to their employer or supervisor symptoms or signs of heat illness in themselves or co-workers

4. The different types of heat illness and its common signs and symptoms

5. The employer's procedures for:

a. Complying with the heat-illness standard's requirements

b. Responding to possible heat illness, including how emergency medical services (EMS) will be provided

c. Contacting an EMS provider and, if necessary, for moving employees to where the EMS provider can reach them

d. Ensuring the EMS provider will receive good directions to the worksite

In addition, employers must train supervisors in the procedures to follow:

1. To implement these provisions

2. When an employee shows symptoms of possible heat-illness symptoms, including emergency response procedures.

Written Procedures: The procedures in item 5 above must be in writing and made available upon request to employees and Cal/OSHA inspectors.

Personal Protective Equipment (PPE): Several Cal/OSH standards in California Code of Regulations, title 8, cover PPE. Here are some that apply to agricultural jobs:

Section 3380 - Personal Protective Devices: While there are few job-specific PPE requirements, the underlying principle is "performance based." Performance-based standards are standards that require an employer to evaluate the task and the type of exposure expected and, based on the evaluation, determine the injuries likely to befall an employee and take measures to control the hazard by using one or more of three methods, in this order of precedence:

1. Engineering controls (e.g., machine guards)

2. Administrative controls (e.g., training)

3. PPE (e.g., safety glasses)

Take, for example, pruners. While no specific regulation pertains to employees who prune vineyards or orchards, eye protection for them may be required. If, upon considering the potential hazards of branches and flying debris that may contact and injure pruners' eyes (because fully effective engineering or administrative controls cannot be implemented), an employer might determine that eye protection for them is necessary to control the hazard.

Section 3380 provides: Protection where modified by the words head, eye, body, hand, or foot means the safeguarding obtained by means of safety devices and safeguards of the proper type for the exposure and of such design, strength and quality as to eliminate, preclude or mitigate the hazard.

PPE must be distinctly marked so as to facilitate identification of the manufacturer.

The employer must assure the employee is instructed and uses PPE in accordance with the manufacturer's instructions.

The employer must assure that all PPE, no matter whether provided by the employer or employee, complies with applicable standards.

The employer shall assure PPE is maintained in a safe, sanitary condition.

PPE must be of such design, fit and durability as to provide adequate protection against the hazards for which they are designed.

PPE must be reasonably comfortable and not unduly encumber the employee's movements necessary to perform his work.

Section 3381 - Head Protection: The question of helmets for ATV operators was answered several years ago in a letter from Cal/OSHA. In that letter, then-Chief of Cal/OSHA, Dr. John Howard, noted: "The ATV's are covered in two sets of regulations. The first regulation is Article 13, Agricultural Operations, in §§ 3437, 3440, and 3441 as Ground-Driven Components and/or Self-Propelled Agricultural Equipment. The second regulation set is in Articles 25 and 27 concerning various types of vehicles where §3650(c), Industrial Trucks, General, deals best with the ATV. The referenced ANSI/ASME B56.8-1988 Safety Standard for Personnel and Burden Carriers addresses "any personnel carrier that does not exceed 35 miles per hour" and lays out a required comprehensive safe-driving program. None of these regulations require helmet use. However, §3441(a) requires mandatory comprehensive training in the use and handling of operating agricultural equipment. In addition, Section 3203(a), Injury and Illness Prevention Program (IIPP), requires implementation of an effective IIPP. Implementation of these programs may require the use of a hard hat or helmet to prevent injury depending on the usage of the ATV."

Cal/OSHA Consultation Manager David Bare conveyed the same observations. However, he pointed out that Cal/OSHA evaluates each situation to determine the potential for injuries and the use of appropriate PPE for that situation - applying, in essence, a "performance based" standard, which Bare believed would generally require that ATV operators wear helmets. Bare gave two reasons for his conclusion:

First, the state requires motorcycle drivers to wear helmets while on public roads and property. Second, ATV manufacturers in their owner's manuals recommend the use of helmets. Because both the state and ATV manufacturers believe that helmets are important safety devices, Cal/OSHA reasons that a strong correlation exists between their use and the prevention of serious head injury if an were to accident occur.

Section 3381 provides: Employees working in locations where they risk receiving head injuries from flying or falling objects and/or electric shock and burns shall wear approved head protection. When head protection is required, the employer shall ensure that approved protective helmets are selected and used in accordance with their demonstrated resistance to impact and electrical hazards.

Each approved protective helmet shall bear the original marking required by the ANSI standard under which it was approved. At a minimum, the marking shall identify the manufacturer, ANSI designated standard number and date, and ANSI designated class of helmet.

Where they risk injury from hair entanglements in moving parts of machinery, combustibles or toxic contaminants, employees shall confine their hair to eliminate the hazard.

Section 3382, Eye and Face Protection, provides: Employees working in locations where they risk receiving eye injuries such as punctures, abrasions, contusions, or burns due to contact with flying particles, hazardous substances, projections, or injurious light rays that are inherent in the work or environment shall be safeguarded by means of face or eye protection. Suitable screens or shields isolating the hazardous exposure may be considered adequate safeguarding for nearby employees.

The employer shall provide and ensure that employees use protection suitable for the exposure.

Where exposed to injurious light rays, the shade of lens to use in any instance shall be selected in accordance with a chart titled "Filter Lens Shade Numbers for Protection Against Radiant Energy."

Required eye protection for employees requiring vision correction shall be provided by safety spectacles with suitable corrected lenses, safety goggles designed to fit over spectacles, or protective goggles with corrective lenses mounted behind the protective lenses.

Employees may not wear contact lenses in working environments having harmful exposure to materials or light flashes, except where special, medically approved precautionary procedures have been established for the protection of the exposed employee.

Section 3383, Body Protection, provides: Body protection may be required for employees whose work exposes parts of their body, not otherwise protected as required by other PPE orders, to hazardous or flying substances or objects.

Clothing appropriate for the work being done shall be worn. Loose sleeves, tails, ties, lapels, cuffs, or other loose clothing that can be entangled in moving machinery shall not be worn.

Clothing saturated or impregnated with flammable liquids, corrosive substances, irritants or oxidizing agents shall be removed and shall not be worn until properly cleaned.

Section 3384, Hand Protection, provides: Hand protection shall be required for employees whose work involves unusual and excessive exposure of hands to cuts, burns, harmful physical or chemical agents or radioactive materials which are encountered and capable of causing injury or impairments. Hand protection, such as gloves, shall not be worn where there is a danger of the hand protection becoming entangled in moving machinery or materials. Wrist watches, rings, or other jewelry should not be worn while working with or around machinery with moving parts in which such objects may be caught, or around electrically energized equipment.

Section 3385 - Foot Protection: Section 3385(a) provides: "Appropriate foot protection shall be required for employees who are exposed to foot injuries ... or who are required to work in abnormally wet locations." Cal/OSHA officials have informally stated that this means that milkers, for example, must wear waterproof footwear when working on milking-barn floors with inadequate drainage.

Accordingly, dairy operators need to provide and maintain rubber "slip-on" shoe covers, rubber boots, or similar waterproof footwear for milkers who work in barns with floors so wet that their feet would become wet if not protected by waterproof footwear.

Similarly, employers should provide and maintain protective footwear for employees, such as irrigators, who work in other types of abnormally wet locations.

Personal Protective Equipment Checklist (PPE) (GISO section 3380)--The employer shall ensure that employees are instructed on where and how to use PPE, which includes equipment designed to protect the body, eyes, hands, ears, and feet. Employees must be trained to:

Wear appropriate gloves and a full body suit when in contact with chemicals.

Use such eye protection as safety glasses, goggles, or face shields when using grinders, saws, buffers, or hazardous chemicals or when taking part in any other activities that could cause eye injuries.

Safeguard against falling objects from trees, such as limbs, branches, buckets, and scissors.

Wear head protection (hard hats, bump caps) with proper eye protection or shields when welding or doing electrical work and when working in areas that are exposed to overhead hazards.

Remove wristwatches and jewelry and secure long hair.

Wear proper respirators for protection against atmospheres that may contain toxic gases, vapors, mists or inadequate oxygen. Such atmospheres may exist in grain vaults, manure pits, tanks, pipes, silos, vats, disposal pits, and equipment repair pits.

Caution: Do not enter a confined space (e.g., silo, bin, manure pit)--even to attempt a rescue--without specific equipment, approval, training and backup support. For more information, call your nearest Cal/OSHA Consultation Office and request a free copy of the Confined Space Guide.

First Aid and CPR (GISO section 3439)--At least one person trained in administering emergency first aid must be provided for every 20 workers. However, if the field is within 15 minutes of a medical-care facility, then trained first-aid personnel and a safety communication system are not required.

What is first aid? It is simply those things you can do for the victim before professional medical help arrives. Train workers in the following:

Providing immediate treatment for injuries

Maintaining first-aid kits, which need to be provided in each foreman's vehicle and/or at the work site

Knowing where first aid kits can be found

Replenishing first-aid materials, keeping them sanitary and in usable condition

Knowing the basics of first aid

Taking precautions against bloodborne pathogens

Reporting all injuries to the immediate supervisor

Using eye wash and showers, available at the work site, in the event of exposure to chemicals

Taking first aid provisions to remote work sites

Knowing the communication system to use in the case of an emergency: radio or cellular phone.

A CPR qualified person should be available to provide required medical assistance to an injured worker within 4 minutes.

Cleaning, Repairing, Servicing, and Adjusting Machinery and Equipment, Including Unjamming Pneumatic Cutters and Conveyor Belts (Lockout/Tagout) (GISO section 3314)--Each year many employees die or are seriously injured on the job because they did not follow proper lockout/tagout procedures.

Whenever employees adjust, clean, or repair equipment, the employer must meet all the requirements of section 3314, including employee training. Field equipment includes machines such as mobile harvesting platforms and pneumatic cutters for broccoli, cauliflower, etc.

When machinery or equipment is stopped, the power source should be de-energized and, when required, the moveable parts should be mechanically blocked or locked out to prevent inadvertent movement.

To minimize the hazards of movement, the employer should require the use of extension tools (extended swabs, brushes, scrapers, or other methods).

To obtain a free copy of the lockout/tagout procedures, contact your nearest Cal/OSHA Consultation Office. This publication is also available in Spanish.

Operation of Agricultural Equipment (GISO section 3441)--Every employee shall be instructed in the safe operation and servicing of all equipment that he or she is assigned to operate.

All guards must be kept in place when a machine or tractor is in operation.

Only operators and other persons required for instruction or assistance are permitted to ride on agricultural equipment.

When servicing, adjusting, cleaning, or unclogging the equipment, stop the engine, disconnect the power source, and wait for all machine movement to stop.

Before starting the engine, engaging power, or operating the machine, make sure that everyone is clear of the machinery.

Lock out electrical power before performing maintenance on agricultural equipment.

All self-propelled equipment, including tractors, must have an operator at the controls when the vehicle is in motion. (See section 3441(b) for exception.)

The driver is prohibited from climbing onto or down from the tractor while it is operating.

Transporting of Employees (GISO sections 3701 & 3702)--Only licensed drivers of the appropriate class shall operate a farm labor truck or bus. Trucks or buses should have at least a 46-inch-high rail or enclosure on the sides and back of the vehicle to prevent falls. The vehicle should also be equipped with handholds, steps, stirrups, or similar devices arranged for the safe mount and dismount of employees.

Manual Lifting and Carrying: Techniques to Avoid Musculoskeletal Injuries--Agricultural workers have a high risk of back injury. Long hours of heavy lifting, carrying, bending, and stooping can lead to back pain or serious injury. You should train your workers on proper lifting procedures using the fact sheet.

Tools: Instruct employees on the following:

Tools that are worn, defective, spliced, or broken should always be replaced or repaired.

Striking tools shall be free of mushroomed or burred heads.

Metal poles or poles that conduct electricity may not be used for fruit picking or nut knocking.

Tree Work and Pruning Operations (GISO section 3428)--Weather conditions such as fog and rain make ladders and shears more slippery. Employees need to take extra precautions in such weather to prevent injuries to themselves and to others. Employees should be instructed to do the following:

Do not throw or drop tools from trees, unless warning has been given and the ground area is clear.

Stop powered saws for all cleaning, refueling, adjusting, and repairs unless otherwise indicated by the manufacturer.

Hang pole saws with the sharp edge pointing away from the employee.

Climbers: Inspect ropes for cuts or abrasions and remove from service any ropes that have deep cuts.

Do not hang pole pruners, pole saws, and pruning shears on utility wires or cables.

Maintain pruning shears; keep them sharp and in good condition. Defective shears must not be used.

Always carry pruning shears with the point facing down when walking or standing.

Always know where your fingers and hands are before making a cut. Hand shears used on grapes pose a special hazard for hands.

Know where your other hand is when you are using a saw, and carry folding saws in a locked position. Folding saws should be sharp.

Be alert and aware of other employees working nearby.

Working at Heights (GISO section 3210)--Guardrails shall be provided on working surfaces more than 30 inches above the floor, ground, or other working surface. Guardrails, toeboards, and stair rails must comply with GISO sections 3209, 3210 and 3214.

Mounted Air Compressors and Air Tanks (GISO section 4070)--Any exposed v-belts must be guarded. A permit for pressure vessels is required if the tank is larger than 1.5 cubic feet or has more than 150 psi.

Emergency Action Plan (GISO section 3220)--Employers are not required to have a written Emergency Action Plan, but if you have one, it should tell the employees what to do in the event of fire and other emergencies. The plan should be kept at the workplace and made available for employee review. This section applies to maintenance shops and fixed structures. Identify the location of the following items on your escape plan:

First-aid kits

Posted emergency numbers

Pipeline valves

Main water valve

Fire extinguishers

Emergency eye wash

Backup communication

Alarm system switches

Chemical storage areas

Are there any critical operations or unique hazards?

Fire Prevention Plan (GISO section 3221)--Employers are not required to have a fire plan (except in lieu of Section 6151(a)), but you should tell employees of any potential fire hazards of materials to which they are exposed. If you have fewer than 10 employees, verbal instruction is sufficient. This section applies to maintenance shops and fixed structures. Employees should be informed of the following:

Safe use of welding and cutting torches

Proper storage of flammable or combustible liquids

Dangers of using damaged electrical cords

Storage of oily rags in enclosed metal containers

Dangers created by smoking and other open flames

Importance of bonding and grounding to eliminate static charge

Classification of flammable storage and fueling areas

Posted warning signs prohibiting sources of ignition

Location of fire extinguishers or other apparatuses (specify)

Initial training, then follow-up training each year if employees are expected to use a fire extinguisher

Note: If the employer does not expect employees to use fire extinguishers at the work site, then a written Emergency Action and Fire Prevention Plan must be in place. The training requirements for the emergency plan and fire plan must also be implemented.

Access to Medical and Exposure Information (GISO section 3204)--Each employer shall inform current employees of the existence, location, and availability of their medical and workplace exposure records. Tell your employees the name of the person responsible for maintaining and providing access to these records.

Hazard Communication Program (GISO section 5194)--You must maintain and develop a written program that gives employees information about hazardous substances to which they may be exposed at the workplace. Employee training must include:

Material Safety Data Sheets (MSDS), reports/records, and information on use of hazardous substances, including pesticides, cleaning agents, fuel, oil, etc., in an accessible location for employee review. (Have information available to take to a doctor in the event of a chemical reaction or chemical contact.)

Location of the employer's list of the hazardous substances that employees use in their work

List of Material Safety Data Sheets (MSDS)

Purpose of the MSDS (to describe the substance[s], the hazardous properties of the substance[s], and protective measures for safe use)

Note: The state Department of Pesticide Regulation and the Worker Protection Standard require a completed Pesticide Safety Information Series leaflet A-8 or A-9 to be displayed in an appropriate location.

Respiratory Protection (GISO section 5144)--If the employer provides negative-pressure respirators, then a written respirator program must be developed and implemented. A respirator program is NOT required when disposable paper dust masks are provided for nose and mouth protection from nuisance dust. However, the employer is required to evaluate the levels of airborne contaminants when reasonably expected to go above the permissible exposure limit PEL). The employer is always required to ensure that no employee is exposed over the PEL. The use of respirators is one way to protect employees from these kinds of exposure. When and where should respiratory protection be worn?

When it is clearly impractical to remove dusts, fumes, mists, vapors, or gases at the source.

When emergency protection against occasional or brief exposures is needed.

In addition:

Employees exposed to such hazards shall use respiratory equipment approved by the Mine Safety and Health Administration (MSHA) or by the National Institute for Occupational Safety and Health (NIOSH).

Employees shall be instructed and trained in the need for and the use, sanitary care, and limitations of such equipment.

Respirators for emergency use shall be inspected monthly and sanitized after each use.

Note: If employees use negative-pressure air purifying respirators for any reason, the employer

must meet all the requirements of Section 5144. Please call the Cal/OSHA Consultation Service for advice when overexposure to contaminants is suspected.

Storage of Hazardous Substances (GISO section 5164)--Substances that react violently, evolve into toxic vapors or gases, have oxidizing components, or have high levels of flammability, explosiveness, or other dangerous properties shall be separated from each other in storage by distance, partition, or other means to prevent accidental contact.

Note: For specific information on pesticide use, contact the office of your county Agricultural Commissioner. Cal/OSHA does not regulate pesticide application.

Top 10 Cal/OSHA Violations in Agricultural Operations

1. Driverless Self-Propelled Equipment (GISO section 3441)--This regulation covers all agricultural equipment, including tractors. Employers must have a tractor operator at the controls while the vehicle is in motion. The employer is required to ensure that if driverless tractors are used, they meet the following conditions:

The equipment is furrow-guided.

The operator has a clear view of other employees and the course of travel.

Brake and throttle controls are within easy reach.

The operator is within 10 feet of the controls and does not have to climb over or onto equipment to reach the controls.

The equipment is not traveling at a speed of over two miles per hour.

2. Machine Guarding Gears, Sprockets, Chains, and Power Take-Off (PTO) Shafts (GISO section 3440)--Employers are required to guard the nip points of all power-driven gears, belts, chains, sheaves, pulleys, sprockets, and idlers. Power take-off (PTO) shafts also must be guarded.

3. Hazard Communication (GISO section 5194)--Employers must have written guidelines informing employees of how to protect themselves from hazardous chemicals used in the workplace. This includes container labeling, employee training, use of material safety data sheets, and an inventory list of hazardous chemicals present on the site.

4. Lockout/Tagout (GISO section 3314)--Employers must have a program that trains employees who repair, service, clean, or adjust machinery (or such equipment as pneumatic cutters) to protect themselves from unexpected energization or start-up of machinery.

5. Guardrails on Elevated Work Areas (GISO section 3210)--Employers must provide guard railing on all walkways, platforms, balconies, porches, and working levels more than thirty inches above the floor, ground, or other working levels.

6. Forklifts, Industrial Tow Tractors, and Agricultural Tractors (GISO section 3664)--Only drivers who are authorized by the employer and have been trained in the safe operations of industrial trucks shall be permitted to operate these vehicles.

7. Injury and Illness Prevention Program (IIPP) (GISO section 3203)--A written IIPP must be implemented and maintained. It must meet the eight requirements for preventing injuries and illnesses in the workplace.

8. First Aid Training and First Aid Kits (GISO section 3439)--There shall be at least one employee trained in emergency first aid for every 20 employees at any "remote location" (i.e., more than a 15-minute drive to an emergency care facility). The employer must provide a first-aid kit at every work site and have a means of communication.

9. Reporting Work Fatalities and Serious Accidents Within 8 Hours (GISO section 342)--Immediately report by phone or fax to the nearest Cal/OSHA District (Compliance) Office any serious injury, illness, or death of an employee in the workplace.

10. Field Sanitation (GISO section 3457)--Employers must provide potable drinking water and single-use drinking cups. Toilet and hand washing facilities shall be located within 1/4 mile or a five-minute walk from the work site. Facilities must be maintained in a sanitary condition. Soap and single-use towels shall also be provided.

Other Safety Issues

Here is a checklist of other safety issues a farm operator may need to address:

Safety Training:

New employee orientation, e.g., workers' compensation insurance coverage, work rules, emergency procedures, hazard communication program, good hygiene practices

Job specific training at time of hire

When assign a new task where no previous training was provided

When a new substance, process, procedure or equipment is introduced into the workplace

When an unrecognized hazard becomes known

Annual equipment operator training, e.g., GISO section 3664

Familiarize supervisors of hazards associated with tasks performed by employees under their control

Specific Training Requirements

New employees, new assignments

Equipment (e.g., tractor, forklift); retrained annually

Emergency action plan training

Fire prevention, fire extinguisher

Lockout/Tagout

Medical responders, first aid/CPR

Respirator users

Confined space entrants and rescue teams

Battery charging

HazMat team (HAZWOPER emergency response activities)

Bloodborne pathogens, doesn't apply to agriculture

Hazard Communication, all substances except pesticides

Hearing Conservation: exposure; testing, and analysis

Ergonomics standard (GISO section 5110)

Two or more Repetitive Motion Injuries, diagnosed by physician, 50% job related, within 12 months

Evaluation, exposure control, employee training

Tractor Roll Over Protection (ROP):

All tractors after 10/26/76, except:

Orchards, hops, vineyards, inside barns and greenhouses, when used with mountable equipment incompatible with ROPs , and stationary power units, e.g., pumping units.

Seat belts