Avoid OSHA fines with a feed mill COVID mitigation plan

Animal Feed for Thought

Jackie Roembke, editor in chief of WATT Feed brands and Feed Strategy magazine and FeedStrategy.com, offers her perspective on happenings in the global feed and grain industries.

Avoid OSHA fines with a feed mill COVID mitigation plan

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National Emphasis Program allows OSHA inspectors to issue citations for COVID hazards at feed mills.

If you’re operating a U.S. feed mill and think the challenges of COVID-19 are behind you, think again. Though infection rates have declined and many restrictions have been lifted, the Occupational Safety & Health Administration (OSHA) will continue to push for employers to conduct risk assessments for COVID transmission.

“The emergency temporary standard is no longer an issue, but OSHA’s formal rulemaking is still an issue. OSHA is working on updating the guidance document, which means enforcement,” said Jess McCluer, National Grain and Feed Association (NGFA) vice president of safety and regulatory affairs, at the 2022 GEAPS Exchange.

OSHA’s COVID-19 National Emphasis Program (NEP) remains in effect, allowing it to “do everything in its existing authority to hold businesses accountable for protecting workers.”

If OSHA receives an employee complaint or if employees become ill, proper recordkeeping will be vital to provide to inspectors who will want to know how the outbreak occurred and what the company did to mitigate the COVID-19 risk.

“It doesn’t look like they’re going to be relaxing the COVID-19 recordkeeping and will still expect a case-by-case analysis,” McCluer said.

In addition, should an inspector come to your facility for another issue and notice COVID mitigation efforts are not in place, an OSHA citation can be issued under the General Duty Clause (GDC).

Develop a COVID mitigation plan

According to the COVID-19 enforcement data McCluer presented at the exhibition, in the U.S. from February 2020 through January 2022, OSHA received 19,279 federal complaints and referrals, and opened 3,359 inspections. Twenty-five GDC citations were issued to companies for not following the CDC guidance.

To avoid an OSHA citation, feed operations should be prepared to present their COVID-19 mitigation plan. Similar to the standard documentation presented during an inspection, managers can refer to the COVID mitigation plan to address an inspector’s questions.

“NGFA is not telling you you are required to do so, but we are strongly suggesting you have your COVID-19 prevention and control plan in place,” McCluer said.

For more information about COVID mitigation strategies in grain and feed facilities, check out NGFA’s COVID Safety Tips.