By Clint Thompson
Without an official heat standard from the Occupational Safety and Health Administration (OSHA), fruit and vegetable producers must consider OSHA recommendations for a heat plan as requirements.
Chris Butts, executive vice president of the Georgia Fruit & Vegetable Growers Association (GFVGA), conveyed that belief following a webinar the association presented in March. The webinar shined a light on the dangers of working in hot temperatures.
“We’ve been looking for a heat standard since October 2021. We’ve got some recommendations, and it’s subjective of an inspector to determine if you’re meeting those or not,” Butts said. “As a grower, it would behoove you to really consider those recommendations as de facto requirements. At the very least, use those as a yardstick to determine if you are being proactive.
“In the eyes of that inspector, there may not be that much difference between a requirement and a recommendation. If we treat those recommendations like requirements, then we may be able to get ahead of the game.”
Write It Down
OSHA’s recommendations include having a written plan in place. This allows growers to better protect their workers and be as compliant as possible.
Who is someone on your farm that can monitor conditions and implement a heat plan throughout the day? Has there been proper training to know how to identify and control heat hazards? How long will it take for medical assistance to arrive at your farm if required?
“We may have a lot of these practices in effect on our farms, but let’s take the time to document those. Put it in writing. Have a plan and be able to share that plan with those regulators when they come,” Butts advised. “It will demonstrate that we are already doing those things. We’ve just got to make sure we’re able to document them and communicate that, both to our workers and to any regulators.”
Concerns Not New
According to Butts, these concerns are nothing new for growers who routinely experience working conditions that exceed OSHA’s guidelines concerning certain temperatures. OSHA outlines that moderate work and heavy work conditions should be adjusted to allow for extensive rest breaks if temperatures exceed 100 degrees Fahrenheit.
“It didn’t suddenly get hot in Georgia. We know how to work in the heat. We know how to take care of our folks, and we know how to be productive when it gets that way,” Butts said. “When we get into those extreme temperatures, I think that you will find that growers are doing all that they can already to limit exposure, whether that be starting early in the day or in the evening and even overnight hours. In those extreme cases, we’re already taking those steps, but we’ve got to be more aware of it on a general recurring basis. It is hot in the summer, and it is hot when our products come to market. We’ve got to be equipped to deal with that, be aware, keep our workers safe and healthy, and provide a good environment for them.”
Staggering Statistics
The March GFVGA webinar highlighted staggering statistics that prompted increased safety measures from OSHA. It has been determined that almost half of heat-related deaths occur on a worker’s first day on the job. More than 70% of heat-related fatalities occur during a worker’s first week. The Bureau of Labor Statistics also reported that 436 people have died due to workplace heat exposure since 2011.
OSHA has also targeted certain segments of agriculture for its National Emphasis Program, with fruits and vegetables comprising a large part of its focus. Certain geographical areas and industries are at a higher risk and are subject to increased inspections and broader enforcement.
Watch Workers
It is also important for farmers to remember that not everyone responds the same way to hot temperatures.
“Everybody is different, and I think that’s one of the things we stressed during the webinar. Have a person on the farm with the crews that is responsible for monitoring heat and heat illness. They need to be familiar with the different symptoms,” Butts said. “Just an awareness and having someone tasked in making sure that everyone is staying cool and hydrated is a good first line of defense — for keeping people safe and for compliance.”
The webinar was an important reminder, as temperatures are about to increase and stay warm more regularly. Producers and H-2A workers will be in the field exposed to soaring temperatures that could stay high well into the fall.
“It’s just like everything else. Sometimes a reminder is good,” said Butts. “If growers don’t have those systems in place, we can provide resources so that as we get ready to get into the heat of the season, we can address it now. Have a plan so that when it does get hot, you are able to implement that plan instead of scrambling at that point to try to come up with a plan,” Butts concluded.