The content emphasizes the critical importance of comprehensive documentation and proactive safety programs, particularly focusing on heat illness prevention and pesticide handling, to ensure legal compliance and worker well-being in agricultural settings.
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it never happened remember that
all of your pesticide
records all of your training records all
of everything it's written down
employees signed what they did
to document that they actually went
through the training etc etc you fixed
something you did proper maintenance on
something everything is written down or
in a court of law it never happened
so heat illness this is an important
subset of worker safety and
and
in sub chapter seven of the general
industrial safety orders group two
safe practices and personal protection
personal safety devices and safeguards
so you drill down you can read the um
um
california government codes
codes
to look at how they deal with heat illness
illness
and heat illness
is something that you need to have a
plan for
what happens when it's too warm
in the field
how do you provide
adequate water
clean cool drinking water to your workers
workers
how do you provide proper breaks
and proper shade areas for them to take
their breaks
and there's specific guidelines some of which
which
didn't make a whole hell of a lot of
sense but i think
most of the
kinks most of the problems have been
worked out
uh to where most companies are doing a
much much better job but
but
the heat illness prevention rules can be
uh incorporated into your
injury and illness prevention program
another acronym
lucky you
you need to know iip as well injury and
illness prevention program or is it
illness and injury doesn't matter um
um
which one comes first it doesn't matter
to me
um but the iipp is your specific plan
on how to deal with everything regarding
your employees injury and illness prevention
prevention
what do you do what is your worker
safety plan
and you're required to have one
and there are great cookie cutter starting
starting
tools where you can start with
some generic iipp and as you go through
it just make changes that make sense for
your company as long as it's applying to
the law but
no injury and illness prevention program
program
or plan
again i don't care if you use program or
plan because i've seen them used interchangeably
it can't know your specific situation
so how much water do you have to make
available to your employees
that is a minimum set by law you can't
change that well i'm only going to give
our employees one quart per day no you
but you can
in your own
company's plan
set up exactly how you're going to
provide shade
there might be shade available in
different ways on different ranches
maybe you have a permanent shade building
building
on one ranch that you can utilize maybe
maybe one of your ranches is
this long thin
row crop area
with some
shade trees right next to it you can use
the shade trees if they're on your robbery
anyway
the iipp is specific to your company
the enforcement of heat illness
prevention is under the division of
occupational safety and health at the
federal level or cal osha
at the california state level so the
ones that really
do the boots on the ground work
are likely the ag commissioner
and occasionally
so what is heat illness
means a serious medical condition resulting
resulting
from the body's inability to cope with a
particular heat load and includes heat
cramps heat exhaustion
heat syncope and
eat stroke
so heat syncope you're getting dizzy
possibly fainting and heat stroke is
near death and
and [Music]
[Music]
it can be surprising how quickly this
can happen
you need to be watching your fellow
workers you need to talk to fellow workers
workers
when i work with crews i encourage them
to pay attention to their work
but talk a little bit
and i don't mean just gossip gossip
gossip but talk about the work talk
about something say something because
when you talk to your fellow worker
that's a red flag you start flaring your
words a little bit
you start saying something that has absolutely
no sense or just
they're confusing and you're like what's
going on
and if somebody starts slurring starts
moving in a funny manner whatever
you're on the verge of it's too it's too
late to catch it early
it's now entering emergency situation
get them to shade
very serious condition you need to know
how to deal with it now
in salinas do we have this kind of a
problem yeah
is it as serious as fresno not at all
fresno has a much bigger problem with
heat illness obviously than we do here
in salinas but
in salinas in a way it has a little more
insidious problems because
we don't
deal with heat that much
we're not used to it that much
my personal situation with heat illness
was mostly because i would have crews
helping with the seed fields over in the
areas of fire bar somewhere like that down
down
past huron south of huron and
it gets really hot out there and i've
got a crew that's including myself
that's been in salinas wearing jackets
now that only happened once but 105
105
from 55
and your body's not ready for it and so
you're taking people who aren't used to
it putting them in an environment that's
too hot
and you got to pay attention you got to
remind people you got to talk and make
sure they're talking okay you got to
make sure they're drinking water
you got to make sure that they're using
the restroom everybody should use the
restroom a couple of times
if they're not they're not drinking
anyway so what do you do to prevent heat illness
illness
water it's one of the main things to do
lots of good clean potable means
drinking water
clean healthy drinking water
has to be in sufficient quantity i think
it's still the same at one quart per
employee per hour
and if that's changed you know i would
suggest you always double check the
rules but i'm pretty sure that is
is uh
uh
a stable number now one quart per
employee per hour
access to shade for at least five
minutes open to the air so it can't be
inside some enclosed
pressure cooker tent structure it has to
be shade and it has to be open air
some sort of ventilation or cooling can
be provided outside of the open air
design depending what you have and the
shade is permitted at all times
depending on the temperature again there
the rules change and i'm not going to
try and quote the temperatures but it
starts getting hot
the rules change
you've got to allow employees to take
these five-minute breaks effective
effective
on 17th of march in 2009
is when the
modern version of heat illness
prevention standard was implemented
there have been minor tweaks to my
understanding since 2009 but
but
the meat of it really happened on this
particular day with that one quart
per hour per worker of water um
um
shade 25 of the crew at a time within
five minute walk of their work area
that one was part of the very difficult
things to impose
in some
ranches when it takes
for some very large blocks
six minutes to get to the center of the
field how can you provide five minute
uh shape well
osha would say break the block up put a
road down the middle of it lose a little
in 2011 there was an audit performed
that found after a couple of years of
this really strong promotion of heat
illness prevention 50 over 50
of the companies audited in california
were out of compliance with the law they
weren't providing enough shade they
weren't providing enough water they
weren't providing
what they what was required under the
law so as a result of that in 2012
uh ocean
calosha developed a heat illness
prevention campaign
to ramp it up and get out to the growers
and they started in an office in
bakersfield which
i'm pretty sure that it's still
nine years later it's still
i think i mentioned this in a previous
presentation but the farm employers
labor service
has a heat illness summary to help
growers understand their responsibilities
responsibilities and
and
it's a great resource for employers for
farm operators to understand not just
about heat illness prevention but about anything
anything
when you're dealing with farm labor
how do you make sure you're following
the law you're providing what's required
and you're doing what you should be doing
so
now we've got the iipp
injury and illness prevention program
uh now if it's injury and illness or
illness and injury on a test i'm not
going to ding you for that or if you use
program or plan i'm not going to ding
you for that but i'm certain that this
one is correct injury and illness
prevention program is what is written
under the law and
and
so this is the at the federal level the
department of industrial relations and
and
everybody has to have
some sort of an illness injury and illness
illness
prevention program in place
that's specific to your company and like
i said you can create
your own
document using templates that are
already there so it doesn't have to be a
monumental task but employers must
then you have to implement it you can't
just say we've got it in a binder on a shelf
shelf
it's not about being in a binder on a
shelf that's step one you actually have
to do all those things in the field you
have to implement it
and you don't just do it once you have
to maintain it which means as things
change you've got to review your
your program make sure that it still
matches your company size the ranches
you have the surrounding environment all
of the things specific to your company
things like who's in charge who do you
call which hospital you go to
if you know an employer
maybe one of the supervisors has to take
a worker to the hospital where do they go
you can't put a generic plan for
everybody in the country you need
something specific to your situation
from your location and maybe you've got
multiple locations so you know if you're on
on
ranches in salinas you're going to go to um
um
salinas valley memorial hospital but if you're
you're
in our
so the program must be effective and it
must be written you can't just say oh we
got a plan
i told all the employees what to do
and they signed a document saying that
they heard me say it no it has to be written
written
it has to be reviewable by employees as
well as
uh the regulatory
authorities at a minimum
an iipp must identify the person or
persons with authority and
responsibility for implementing the
program who's making sure this program
is happening it must include a system
it's not all the responsibility of the employer
employer
employees must comply if you've got a
hard hat area where employees must wear
hard ads
you need to train them there first
you should post it
you know hard hat area on a sign
but then employees must follow that rule
they if they go into that area they got
what do you do if they don't
there has to be some sort of a system document
document
uh reprimand even fire employees who
don't comply who don't follow safety
rules they put everybody at risk
the iipp must include a system for
communicating with employees in a form
readily understandable by all affected employees
employees
you can't have
you know a posting in mandarin when your
employees speak spanish
it has to be a language they understand
trainings they understand
documents meetings
on and on there are lots of ways to
communicate and
in every company i've ever been in it's
a combination of these things it's a
combination of trainings postings handouts
handouts uh
uh
postings can be
very simple bold hard hat area sign
or they can be more detailed break room
lists of forklift safety rules that sit
on the wall in the break room so
you know you train your employees on it
and then whenever they want to review
while they're eating lunch it's right
there on the wall
they can sit there and read it
lots and lots of ways
to follow the rules a lot of times i've
seen in the fields where um
um
there are posters all over the bathrooms
in order for the company to say yeah
we're complying with the law we're
posting this do employees actually read
what's on a
porta potty out in the field
probably not is that the most effective
way of doing it
you better be doing something else it
complies with the law but it's probably
not reaching very many employees
iipps must include procedures for
identifying and evaluating workplace hazards
hazards so
how do you find what are the hazards
and what happens when those change you
start doing things differently get new
equipment new
chemicals new uh machinery
machinery
new ways of doing things on and on and
on that are
things that are new that you didn't have
five years ago when you first wrote the iep
the iipp must include a procedure to
investigate occupational injury or
occupational illness what do you do when
something happens
just because you have
an iipp doesn't mean nobody will ever
get sick or injured
it reduces the likelihood hopefully
and it reduces it substantially but
eventually somebody's going to get hurt
what do you do
what's the procedure
how do you look into it how do you
figure out what happened what went wrong
why did somebody get hurt
what what can we do to prevent this in
the future so nobody else gets hurt in
the iipp must include methods and or
procedures for correcting unsafe or
unhealthy conditions work practices
and work
procedures in a timely manner
and based on the severity of the hazard
so for example the
the pto
pto shielding
shielding
breaks free
you can't use it anymore
that piece of equipment is too dangerous
without the shield
you need to get somebody in there a
welder a fabricator somebody to fix it
but there's a nail coming up a little
bit on a loose stair and you know it's
fine you know you just don't want
somebody to trip on that loose stair so um
um
you get a work order and it's going to
be done on friday no problem
minor severity minor issue
highly unlikely it could possibly have a problem
problem
get to it soon
if it's truly dangerous
stop work
until it's fixed or handled
and again the details of this
depends there's lots of court cases and
precedent to make it clear
iipps must provide training and instruction
instruction
when the program is established at the
very beginning everybody gets trained
anytime a new employee comes on that new
employee must be trained
and the challenge with new employees is
you've got a lot of things you got to
deal with the iapd you got to deal with
pesticide training
you've got all these things you need to
train an employee on before they can go
to work
if an employee is given new job
assignments they're going to be doing
something new in a new area well that
whenever new substances processes
procedures equipment blah blah blah
there's a new hazard
if there's a new or previously
unrecognized hazard so
you have your perfect eye ipp and
somebody points out maybe an inspector
maybe an employee hey we really should have
have
uh some safety on this uh-oh we missed
that before
better train everybody on it it's been
newly identified
and to familiarize supervised to
familiarize supervisors with hazards to
employees under their immediate
direction and control so it's not just
the employees but
everything that those employees do under
the supervision of a given supervisor
that supervisor needs the same training
that everybody under that supervisor has
so they understand all of the safety
issues for everybody
so the iipp records must include
scheduled and periodic inspections
safety and health training records
and all of these records must be
maintained for at least one year and
and
i would advise that you
consult your
uh corporate attorney or whoever
is responsible for
your legal
obligations for the company
to find out how long is too long
sometimes keeping records for too long
has its own
potential pitfalls
not too likely in iipps but always
double check all right we need it for
less than one year but at what point do we
we
do we throw things out do we go through
them every six months
and anything that's older than 18 months
but it is good to review your records
and shred things that are getting too old
old
it's always a good idea
and i will defer to your corporate
attorney to determine what is too old
that could present challenges or
potential liability if you hold on to
pesticide safety the california
code of regulations
six pesticide and pest control
operations under the california
department of pesticide regulation california
california dpr
employers of pesticide handlers must
have a written training program for the employees
employees
so this is different
because it's pesticides
and it's a different area so you need a specific
specific
training program
just for pesticides and
to be a handler is a specific category
of training if you are just incidentally
involved because maybe you're part of a
harvest crew you're going into a field
that was previously sprayed
you're not handling the pesticides but
you're going into fields after the
reentry or restricted entry interval is elapsed
elapsed
so the rei is over you're going into the
field you need training about working
around places that have been sprayed
with pesticides
but you're not handled
the handlers have a higher level of training
training
and because of the dangers of pesticides
handlers must be retrained every single
single year
year
so there's a hazard communication
program for pesticides including what's called
called
the safety data sheets this is an old
term they used to be called material
safety data sheets msdss
now they're just called safety data
sheets sds
and occasionally you still run across
the term material safety data sheet or msds
msds
but i don't know how long it's been probably
probably
i don't i don't want to venture a guess
but it's been a number of years that the
m has been dropped and they just call
them safety data sheets and you need
safety data sheets for every single
pesticide used and
and
you might need them for osha as well i
needed to have safety data sheets
for the
toilet bowl cleanser that i got from safeway
safeway
that was under the sink because it is a
chemical that is dangerous
you can't drink
the toilet bowl cleaner
and it's at a work site i needed a
safety data sheet in my binder for the
toilet bowl cleanser in
in
the uh
everything you need the safety data
sheets provide periodic cholinesterase
blood tests under certain conditions
certain pesticides
react if you get contaminated they react
in a way that you can detect it in your blood
blood
if you've been exposed especially
especially small
small
excessive dose exposures over a longer
period of time you can have
these cholinesterase
levels that would indicate you've had
excessive exposure so
so
you keep an eye on it
you keep an eye on your employees you do
these quick and easy inexpensive blood
tests to make sure
that they're not showing any kind of
signs of exposure to pesticides
certain pesticides
you have to have a written respiratory program
program
how do you
get proper fitting proper training proper
proper uh
uh
choice of filters
for the chemicals you use et cetera et cetera
cetera
the employees
must require people working alone with
restricted pesticides labeled dangerous
to have contact with another person
every two hours during daylight and
every hour at night
and i've got an easy solution to this
nobody's ever alone if they're working
with dangerous pesticides ever
ever
is that required under federal law no
but i think it's a good idea somebody's nearby
nearby
what about contractors they're not
necessarily your employees you have
labor contractors doing harvest
operations maybe weeding and thinning
there are number of things you might
have some plumber coming to your site to
they know nothing about agriculture they
should know about plumbing
they're on your site they must be
notified of areas
of pesticide applications
and areas where entry is restricted
you've got to keep people informed and
just because they're not your employees
if they're coming onto your property for
any reason they need to be notified and
even if somebody drives off the side of
the road to steal your strawberries
they need to be notified how by putting
see the agricultural hazardous materials
transportation endorsement
on their specific driver
driver training
training and
and
so there's specific
requirements if you're driving trucks
with pesticides in it so the dl267 holders
holders
the holders of this certificate are
exempted from the hazardous materials
provisions of the california commercial
driver's license program including but
not limited to drug and alcohol testing
won't get into the specific of that but
you need to know
be in compliance with the department of
transportation d.o.t and
and
that's what dot is department of transportation
you need to make sure that you know
what your drivers are required to do
are they
transporting these materials well
commercial truck drivers bring a
shipment of pesticides from the
manufacturer to a to an outlet a retail
outlet that's a different scenario than
one of your
field supervisors bringing some
pesticides to the applicator out in the
field from your warehouse to the field
very different things you need to make
sure you know and i don't even want to
try to get into that here
um but when you're putting pesticides in
a vehicle and transporting it
you better know
what is and is not legal
tractor and equipment safety let me take
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