Dairy processing facilities are complex and sprawling sites featuring modern engineering and technology. At the heart of any dairy plant is a team of dedicated employees working hard to instill a safety culture that permeates every aspect of the business and ensures compliance with regulations from the Department of Labor’s Occupational Safety and Health Administration (OSHA).
Safety representatives, including line managers and supervisors with adjunct safety responsibilities, regularly engage with OSHA regulatory officials. The interaction can be reactive (such as responding to unannounced compliance inspections) or proactive (such as partnering with a local OSHA compliance assistance specialist or participating in OSHA’s Safe + Sound campaign to promote awareness and understanding of a companywide approach to workplace health and safety).
A new initiative
Seeing a new opportunity, the International Dairy Foods Association (IDFA) and our Environmental Worker Safety (EWS) Committee began a new initiative to elevate the dialogue and collaboration between OSHA and the dairy processing industry.
OSHA has welcomed the request from the dairy sector for enhanced communication. In a recent call hosted by IDFA, regulators discussed some common inspection issues for dairy processors, and safety leaders had the opportunity to ask questions and share comments with regulators. Regulators provided specific references that are a key focus for OSHA and all manufacturing — for example, the sequencing of lockout/tagout procedures that ensure machines are properly shut down and not started again before maintenance or repair work is completed.
The regulators also outlined OSHA’s compliance-assistance program for small employers, which provides services for hazard identification and correction and assistance in developing safety and health programs. These services are available through local OSHA offices at no cost and can offer some exemption from OSHA’s programmed inspections.
This month, OSHA will present a webinar to the IDFA EWS Committee that takes a deep dive into the Process Safety Management (PSM) standard that is central to avoiding and mitigating risks associated with ammonia refrigeration systems. They will likely include the top 10 issues for PSM facilities and provide guidance for facilities with low-charge ammonia systems (less than 10,000 pounds) that are not required to comply with the PSM standard.
A team of OSHA regulators will meet with committee members at ProFood Tech, scheduled to take place March 25-27 in Chicago, to share how OSHA is regulating combustible dust and to discuss other timely safety topics.
Benefits for both parties
By elevating communication with OSHA, operations leaders and facility safety professionals can improve their understanding of how the department’s regulations are developed and enforced. They’ll also better understand other policies that affect the dairy industry and worker safety.
This effort also aims to improve the expertise of OSHA regulators charged with inspecting the technology, equipment and unique refrigeration systems at dairy processing facilities. By regularly meeting with regulators, safety professionals can provide constructive feedback in a non-adversarial forum.
Through this ongoing initiative, IDFA’s EWS Committee members will invite OSHA regulators to visit their dairy processing facilities to see how anhydrous ammonia systems are built and operated. OSHA regulators who understand the unique dairy processing technologies and processes, and their respective risks, are less likely to misapply OSHA standards during an inspection and cause a dairy company to spend resources defending itself from unwarranted enforcement actions.
IDFA and its member companies believe this initiative is the start of a new and improved relationship with OSHA, raising the bar for both the regulator and the regulated.
