OSHA Audits and Hazard Communication

There are many goals towards which good dairy herd managers strive, often focusing around production, health and reproduction. As farms employ more non-family employees, having an effective employee health and safety program is not only a good goal to implement, but one that can prevent injuries and accidents.

Last year OSHA approved a Local Emphasis Program (LEP) for Wisconsin allowing for OSHA inspections on farms that have employed more than 10 non-family employees OR have had an active temporary labor camp in the last 12 months. This exempts small farming operations not meeting either standard.

Hazard Communications

Of the 12 common hazardous activities addressed under the LEP, many citations on dairies are given for Hazard Communication, which OSHA defines as "Serious chemical ingestion, absorption, splash, fire or other hazards may exist where hazardous chemicals are stored, dispensed, and used without appropriate training and information including the availability of Material Safety Data Sheets (MSDSs)." These products include teat dips, hoof care products, footbath concentrates, parlor sanitization products, pharmaceuticals, etc.

To pass OSHA’s test in hazard communication, dairy farms need to have a Hazardous Communication Program addressing the following areas:

Material Safety Data Sheets, Hazardous Materials Inventory Lists & Labeling

MSDSs and an inventory list of all hazardous chemicals used in the workplace are required to be readily accessible to locations where hazardous chemicals are used, stored or dispensed. Spanish MSDSs may be necessary to accommodate a bilingual workforce.

All containers, including secondary containers, holding hazardous chemicals must be properly identified and labeled with health hazards. Chemicals should not be used unless properly labeled.

Employee Training and Information

Proper employee training covers all hazardous chemicals present in the workplace, their locations, as well as when and how to use. Labels and MSDSs should be reviewed, both in location and interpretation. Employers are also responsible for developing and training employees on emergency procedures, understanding symptoms of overexposure, and providing them with personal protective equipment.  

A thorough employee training program will consist of training for new hires, non-routine tasks or accidents, emergencys and for new hazards.  

A written Hazard Communication Program will assign responsibility and accountability to individuals, should be visible to employees, and most importantly serve as a resource to keep your employees safe.  

ANIMART has MSDSs available in both english and spanish, as well as personal protective equipment and chemical charts for employee safety. Contact your sales representative for more information.

Sources: OSHA, National Farm Medicine Center