Protecting Seasonal Ag Workers with a Non-Routine Work Program

By Gina Ekstam | February 22, 2021

During a routine trip to dump grain into a dump pit, a driver became concerned about the amount of dust rising from the pit.

To investigate, he removed both the primary and secondary pit grates — a task that was not a routine part of this job. As he was preparing to replace the secondary grate, he tripped over the primary grate and fell into the pit, causing injuries to his head, neck, shoulders and knees.

In a short amount of time, more than $200,000 in claims were paid or in reserves.

In this example, the worker is a seasoned, full-time employee performing non-routine work. If an accident like this can happen to a seasoned, full-time worker, consider the risk non-routine work poses for the thousands of seasonal agricultural workers in the U.S.

According to the National Center for Farmworker Health, there are about 2.5 million to 3 million agricultural workers in the U.S. Eighty-four percent are seasonal workers. They are essential to U.S. agriculture — hired to plant, cultivate and harvest crops during peak production.

Agriculture is among the most hazardous industries, with about 100 workers injured every day and a fatality rate of 20.4 deaths per 100,000 workers, according to The National Institute for Occupational Safety and Health (NIOSH).

The nature of temporary, seasonal work means that workers have little to no experience performing necessary tasks, or they forget how to perform a task or how to use specialized equipment. This non-routine work puts them at risk for serious injury.

In the event of an OSHA investigation, employers should be prepared — through documented files — to answer the following questions:

  • Do workers perform this kind of work routinely?
  • How are workers informed of the potential hazards of the work?
  • Are workers trained on how to protect themselves from potential hazards?

Defining Non-Routine Work

Each agribusiness operation may define non-routine work differently. For example, the definition could even be :”any work that is not conducted on at least a quarterly basis by the persons assigned the task.”

Jobs and tasks that are not performed on a regular basis or are being performed for the first time are considered non-routine work.

Non-routine work includes tasks that are:

  • Performed infrequently;
  • Outside of normal duties;
  • Do not have a documented procedure;
  • Performed differently from the documented procedure;
  • Have never been performed before.

Any work that meets the definition of “non-routine” must go through a job hazard analysis.

Developing a Non-Routine Work Program

A job hazard analysis, the first step in developing a non-routine work program, is an active approach to workplace safety. Defined by OSHA as a process of “carefully studying and recording each step of a job, identifying existing or potential job hazards (both safety and health), and determining the best way to perform the job to reduce or eliminate these hazards.”

The hazard analysis involves five steps:

1. Select and prioritize the job to be analyzed. Non-routine work should be a top priority due to higher incident rates. Employers should also consider accident frequency, accident severity and repeated exposure to a hazard.

2. Separate the jobs into basic steps or tasks. Gather as much information as possible during a job site walk-through. Use photos and notes to document working conditions, equipment, supplies and chemicals. Use this information to identify all the steps required to complete the task, as well as the hazards and safety controls associated with the work.

3. Identify the hazards within each step. For each step identified, ask the following questions to determine if a hazard exists:

  • Can the worker forcefully strike against anything?
  • Can anything move and hit the worker abruptly or forcefully?
  • Can the work come in contact with electrically charged equipment?
  • Can any part of the body be caught between something moving and something stationary or between two moving objects?
  • Can the worker slip or trip on anything that would result in a fall?
  • Can the worker fall from one level or another?
  • Can the worker be injured while lifting, pulling, pushing, twisting, reaching, bending, or another motion resulting in a sprain or strain?
  • Can the worker be exposed to excessive noise, vibration, extreme temperatures, poor air circulation, toxic gases, airborne dust/fumes or hazardous chemicals?
  • Can the worker be engulfed or entrapped by material?

4. Control each hazard. Once all hazards are identified, it’s important to evaluate each one to eliminate or reduce the potential hazard. Consider the following control measures:

  • Can the hazard be physically removed or replaced?
  • Is it possible to isolate people from the hazard?
  • Is there a way to change how the work is completed?
  • Is personal protective equipment available to protect workers?

5. Revisit and revise the analysis. A hazard analysis is only effective if it is reviewed regularly or after an accident occurs. This important step helps find hazards that may have been missed in an earlier analysis. It also helps to determine whether new procedures or protective measures are needed.

When the hazard analysis is complete, the next step is the development of a formal, written documentation detailing plan procedures and hazard control measures. A safe operating procedure manual should establish a logical order of each task necessary to perform the work. For each task, detail the actions required to eliminate, control or reduce hazards.

The final step in creating a formal non-routine work program is employee training. Instruct employees on proper procedures, describe the hazards associated with each step, and explain what measures are required to eliminate, reduce or control exposure. Document all training completed, including names and signatures of the instructor and participants.

Ongoing review of the non-routine work program helps improve processes and worker safety. Conduct frequent inspections of the tasks and safety controls and be sure to document everything.

Make Safety a Priority

Risk is inherent in many situations. It is important to remember that when risk exceeds what we plan for, we must step back and re-evaluate our actions/behavior. This is a continuous process that requires employees at all levels to be engaged and working together to create a safe workplace.

OSHA’s Hazard Communication Standard describes the requirements for non-routine tasks:

  • Provide workers with written documentation describing the task-related hazards, in language workers understand.
  • Provide specialized training on protective controls.
  • Test worker understanding of the information before the non-routine task is performed.

From the first interview, it should be clear that safety is a priority. Complying with OSHA’s Standard means that employers should provide new workers clear and detailed instruction on:

  • How to safely perform the work they are hired to do (even if it seems a task needs no instruction);
  • How to operate the tools, machinery and safety equipment required to perform their work; and
  • What personal protective equipment (PPE) must be worn, and how to correctly wear it.

Every job comes with a set of risks. Employees should understand the hazards, know what steps to take to avoid them, and understand what steps to take if an incident occurs. Further, workers should feel comfortable speaking up about any safety concerns they have.

Seasonal workers are at a higher risk for injury. In addition to receiving proper training, these workers should not deviate from the work they are hired to do.

Conclusion

In fields and factories across the country, seasonal workers work long hours, stooping, climbing, carrying heavy loads, handling pesticides and operating specialized equipment to produce and harvest the crops that feed our families.

In the grain pit example, AssuredPartners consultants engaged the client in an active investigation dialog to detail what happened, why it happened, and how to prevent it from happening again. This critical discussion led to the creation of a formal non-routine work program with specific instruction on how to safely complete tasks, along with ongoing employee training and communication.

It is the employer’s responsibility to provide a safe work environment and the necessary training for all employees. Specific attention to non-routine work is an essential component for every agribusiness operation.

About Gina Ekstam

Ekstam is managing director, agribusiness vertical leader at AssuredPartners

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