On most every farm, there are discussions dealing with the proposed new EPA water regulations. These new regulations, if enacted, will definitely have a major impact on every farm. But they are not the only concern facing a farm operator. I would argue that the lack of true training programs on the farm are of greater immediate concern. Even if you properly train your employees, there can still be fines because your paperwork is not in order.
Elections have consequences, and even though the propagation of new regulations is a long and detailed process, there is nothing that can stop a given administration from implementing what they see as their mandate. One area of regulation that has been in place for many years and also ignored for many years are those dealing with the proper training of employees and the records of that training. Who has been trained and who has not? Ever send a new employee to the “shed” to get something? Because they were not yet trained or the training was not documented, you could have just violated a regulation and could be subject to a fine or worse.
The real issue is that there has been little or no enforcement of training requirements on the farm. This means training has not been a major area of concern for ag employers.
This is all about to change.
Given the number of laws, agencies and regulations currently in place — federal and state — no one could ever provide a complete listing of everything every employer must concern themselves with in the training area. Therefore, I will not even try. What follows is simply the list that came to mind as I wrote this article.
I must begin with the Occupational Safety & Health Administration. At present, OSHA is planning a very detailed and targeted inspection of larger New York dairy farms. They are calling the program the Local Emphasis Program, or LEP. Beginning in July, they will be making surprise inspections to New York dairy farms. They will not only be inspecting the physical farm for safety compliance, but will also be examining each farm’s training records! You know those records you either never kept or that you stopped keeping many year ago since no one ever asked for them. Remember, that even if you do everything right in the worker protection and training area, the lack of records carries fines.
Some other areas where employee training, records of training and implementation of training are essential are:
Manure Management Act and the Manure Management Manual.
EPA Worker Protection Standards and related signage.
U.S. Department of Labor regulations and PA New Hire Reporting.
Health Insurance Portability and Accountability Act that demands that employee health records be properly protected, and Patient Protection and Affordable Care Act requirements.
Good Handling Practices and Good Agricultural Practices for fresh fruit and vegetable growers.
Food and Drug Administration drug guidelines and audit program.
Editor’s note: Michael Evanish is the manager of MSC Business Services, a member service of the Pennsylvania Farm Bureau. For more information, call 717-731- 3517.