Newsletter

Volume 29

 

Aug 12, 2019

Celebrate Safe + Sound Week Along with ResponsibleAg

According to the U.S. Bureau of Labor Statistics, more than 5,000 workers are killed on the job (a rate of 14 per day), and more than 3.6 million suffer a serious job-related injury or illness. These injuries hurt workers, their families, communities and businesses.

As an organization committed to safety, ResponsibleAg is a proud supporter of OSHA’s nationwide Safe + Sound Campaign, which was launched in 2017 to raise awareness of the value and importance of workplace safety and health programs. Through this program, OSHA provides a variety of valuable resources, consultations, webinars and training to help companies establish and continuously improve their safety compliance. Last year, more than 2,700 businesses helped raise awareness about workers’ health and safety.

Join ResponsibleAg in supporting Safe + Sound Week, August 12-18. Check out the OSHA Safe + Sound website

Credentialed Auditor Dinner and NAEHSS Safety School Just Around the Corner. Sign Up Today!

Don’t delay in signing up for two important August industry events that will be held at the Asmark Institute Agricenter in Bloomington, IL.

• ResponsibleAg Dinner for Credentialed Auditors – August 20 This special dinner event takes place Tuesday, August 20th and recognizes the important work of auditors. Since ResponsibleAg began in 2014, more than 2,950 audits have been completed by 135 credentialed auditors. In addition, 1,425 facilities have been certified. These achievements would not have been possible without our credentialed auditors. Social hour begins at 5 p.m. with dinner following at 5:30 p.m. R.S.V.P. by August 15th by contacting the Helpdesk at 270-683-6777 or by emailing Helpdesk@ResponsibleAg.org.
• Annual National Agronomic, Environmental, Health and Safety School – August 20-21 The annual NAEHSS safety school is set for Tuesday and Wednesday, August 20 and 21, and will feature industry, state and federal agency experts talking about the latest regulatory updates. In addition, participants will have the opportunity to network with Environmental Health and Safety School peers. Get more information and register by visiting naehss.org.

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Don’t Forget to Register with ResponsibleAg - Recertification Required Every 3 Years

Nearly 3,000 facilities have registered with the ResponsibleAg Certification Program, and 1,425 facilities have received their initial certification. We encourage you to register your facility today and remind you to schedule your audit for re-certification which is required every three years! For more information, go to Responsibleag.org.

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Large or Small, Safety is for All

When it comes to safety regulations, size doesn’t matter. In the August Faces of ResponsibleAg, Alan Mahoney, former Safety, Environmental and Regulatory Manager for MFA Incorporated and a current Credentialed Auditor for ResponsibleAg, talks about the resources and unique benefits ag retailers ‒both large and small – can reap by participating in ResponsibleAg.

Read this and all Faces of ResponsibleAg articles in the News section of ResponsibleAg.org. You can also find this article in the August CropLife magazine.

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Lockout/Tagout Standard – Comment by August 18

A few short days remain to comment on a possible update to the Control of Hazardous Energy - Lockout/Tagout (LOTO) standard. OSHA is interested in comments on the use of control circuit-type devices to isolate energy, as well as the evolving technology for robotics.

Comments must be submitted on or before August 18, 2019. Comments and materials may be submitted electronically and identified by Docket No. OSHA-2016-0013, or by mail or fax

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ResponsibleAg Leaders to meet during TFI’s World Fertilizer Conference in Chicago, September 23-25

The ResponsibleAg Board of Directors and Communications Committee will both hold their annual in-person board meetings in Chicago in conjunction with TFI’s World Fertilizer Conference. If you’re attending, please be sure to say Hello or touch base with them if you have questions or comments about ResponsibleAg or the ResponsibleAg Certification Program.

If you’ve never attended the World Fertilizer Conference, you may want to consider going. The conference draws more than 700 people from 60 different countries representing all sectors of the fertilizer industry. From the impact of the Green New Deal to the risks of climate change and related policies, speakers at the conference will discuss the disruption in the fertilizer industry. To learn more about TFI’s Conference or to register, click here.

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Prepare Now to Hire Drivers for Spring 2020

Spring 2020 may seem months away, but it’s not too early to create an action plan to hire drivers for one of your busiest times of year ‒ especially because the Department of Transportation’s Entry-Level Driver Training (ELDT) rule becomes effective in the spring. The new rule will be especially important for drivers who are:

• Trying to obtain a Class A or B commercial driver's license (CDL)
• Upgrading to a Class A or B CDL
• Obtaining a Hazardous Materials Endorsement (HME)

The new ELDT rule imposes minimum training requirements, including mandatory theory or knowledge training and a behind-the-wheel training program. To obtain an HME endorsement, the mandatory theory training must be provided by a training provider listed on DOT’s Training Provider Registry. The rule also includes a training curriculum specifically for drivers seeking an HME. Because of these changes, companies that have “grown their own” drivers in the past may need to rely on drivers who are trained elsewhere.

Those who don’t take time to prepare in advance could face dilemmas in spring 2020 when advertising for drivers, but no one applies — or many people apply, but expect the employer to train them before they can work. Hiring drivers is going to require some planning and strategy. If you haven’t done so already, start discussing hiring plans now in your company. For more information, check out this Entry-Level Driver Training FAQ from the Federal Motor Carrier Safety Administration.

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Audit Issues Awareness – #5 Spare Fuses – DOT

Number 5 on the ResponsibleAg list of Top 25 Audit Issues is Spare Fuses. The DOT requires that motor carriers ensure each self-propelled commercial motor vehicle is equipped with fuses that are needed to operate any required parts and accessories. Each vehicle must carry at least one spare fuse for each type/size of fuse needed for those parts and accessories.

Do you need more information about these and other requirements and documentation? ResponsibleAg participants can quickly access all the details by visiting the online Compliance Assistance Library. Within each compliance assistance document, there is a link to complete information about the regulations in question.

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Provide Water, Rest and Shade to Protect Workers from Heat - It’s the Law

The ancient Romans called the hottest, most humid days of summer the “dog days," because they followed the rising of Sirius, the dog star. The Romans connected the dog days with heat, drought, sudden thunderstorms, lethargy, fever, mad dogs and bad luck. The modern-day Dog Days of Summer occur in August, when we often see the hottest days of the year ‒ a time when employers must take steps to protect workers from extreme heat. OSHA law requires employers to provide workplaces free of known safety hazards. OSHA’s Heat Illness Prevention Campaign comes down to three words – Water. Rest. Shade.

Take precautions against outdoor heat with the OSHA-NIOSH Heat Safety Tool, featuring a real-time heat index and hourly forecasts specific to your location, as well as occupational safety and health recommendations. The Heat Safety Tool is a useful resource for planning outdoor work activities based on how hot it feels throughout the day. For more information on ways to protect your employees, visit the OSHA website for information on Occupational Heat Exposure.

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News from Around the Industry

EPA Announces FY 2020-2023 Priorities

The Environmental Protection Agency recently announced seven enforcement and compliance assurance priority areas for fiscal years 2020-2023. Six of the seven priorities are National Compliance Initiatives (NCI), which will be led by EPA’s Office of Enforcement and Compliance Assurance (OECA).

Priorities for Improving Air Quality

• Creating Cleaner Air for Communities by Reducing Excess Emissions of Harmful Pollutants from Stationary Sources: focus on reducing emissions of volatile organic compounds and hazardous air pollutants.
• Reducing Hazardous Air Emissions from Hazardous Waste Facilities: focus on getting hazardous waste treatment storage and disposal facilities and large quantity generators to improve compliance with regulations for controlling and monitoring organic air emissions from certain hazardous waste management activities.
• Stopping Aftermarket Defeat Devices for Vehicles and Engines: focus on stopping the manufacture, sale and installation of aftermarket defeat devices on vehicles and engines used on public roads, as well as on nonroad vehicles and engines.

Priorities for Ensuring Clean and Safe Water

• Reducing Significant Noncompliance with National Pollutant Discharge Elimination System (NPDES) Permits: focus on increasing the compliance percentage of all NPDES permit holders.
• Reducing Noncompliance with Drinking Water Standards at Community Water Systems (CWS): focus on working with the EPA’s Office of Water to increase the capacity of states, tribes and the EPA to address drinking water violations.

Priorities for Reducing Risk from Hazardous Chemicals

• Reducing Risks of Accidental Releases at Industrial and Chemical Facilities: will focus on reducing risks to human health and the environment by decreasing the likelihood of chemical accidents.

Lead Action Plan

• Rather than develop an NCI to address lead exposure, the OECA will contribute to the agency’s goal of reducing childhood lead exposure and associated health impacts as outlined in the Federal Lead Action Plan that was issued by the President's Task Force on Environmental Health Risks and Safety Risks to Children in December 2018.

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New Expiration Date for Medical Examiner’s Certificate ‒ Nov. 30, 2021

The Department of Transportation has changed the expiration date of the Medical Examiner’s Certificate to 11/30/21. The new date replaces the previous expiration date of 9/30/19 for Medical Examination Report Form MCSA-5875 and Medical Examiner’s Certificate MCSA-5876.

Representatives of J. J. Keller & Associates Inc. initially reached out to DOT in December 2018 about extending the grace period to continue using forms with an expiration date of 8/31/18. DOT reversed its initial decision and continued accepting the older version but encouraged use of the updated form dated 9/30/19. DOT has not identified a cutoff date for using forms that expire on either 8/31/18 or 9/30/19. Currently, all three versions remain acceptable, but use of forms dated 9/30/19 or 11/30/21 is advised. A big thank you to J.J. Keller for monitoring these updates.

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DHS to Expand Personnel Surety Program to Tier 3 and 4 Facilities

The White House Office of Management and Budget has given the green light to a Department of Homeland Security (DHS) proposal to expand the Personnel Surety Program of the Chemical Facility Anti-Terrorism Standards (CFATS) program. DHS received the authorization to expand the program to cover more than 3,000 CFATS facilities in risk Tiers 3 and 4. Most agricultural retailers that are subject to CFATS are considered Tier 3 or 4.

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Top-Screen Re-submissions

Have you checked when your facility last completed an updated or revised Top-Screen survey? DHS requires Tier 1 and Tier 2 covered chemical facilities to submit an updated Top-Screen every two years; Tier 3 and Tier 4 facilities must submit an updated Top-Screen every three years.

To help facilities keep track of this requirement, DHS sends a reminder letter through the Chemical Security Assessment Tool (CSAT) portal when it’s time to submit an updated Top-Screen. When a facility logs into CSAT, the Top-Screen will be open and waiting for completion. Facilities have 60 days to complete the Top-Screen once notified to do so.

If your covered facility makes material modifications to its operations or site at any time, a revised Top-Screen must be completed and submitted within 60 days of the material modification. As a best practice and to ensure efficient reporting processes, facilities are encouraged to predict and report the highest expected quantity of a chemical of interest (COI) and all variations of concentration and packaging they anticipate possessing at a given time over the operation’s lifecycle. Following this approach means a facility will not need to resubmit a Top-Screen when the COI quantity or concentration is reduced through normal operations.

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DOT Accepting Applications for Under 21 Military CDL Pilot Program

DOT is accepting applications for a pilot program to permit 18- to 20-year-olds who possess the U.S. military equivalent of a commercial driver’s license (CDL) to operate large trucks in interstate commerce. “This program will help our country’s veterans and reservists transition into good-paying jobs while addressing the shortage of truck drivers in our country,” says U.S. Transportation Secretary Elaine L. Chao.

Under Section 5404 of the Fixing America's Surface Transportation (FAST) Act, the pilot program, will allow a limited number of individuals between the ages of 18 and 20 to operate large trucks in interstate commerce—provided they possess the military equivalent of a CDL and are sponsored by a participating trucking company. During the pilot program, which is slated to run for up to three years, the safety records of these drivers will be compared to the records of a control group of drivers. Veterans and reservists are encouraged to apply and to learn more about this new program.

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Welcome ResponsibleAg Credentialed Auditor

After a full house for the June Auditor Training course, ResponsibleAg is excited to announce these individuals are now credentialed and available to audit ag retail facilities throughout the United States.

Beril Yalcin ― International Raw Materials LTD - Philadelphia, PA<
Bob Bonner – Nutrien - Bella Vista, AR
Derek Samples – Greenpoint Ag - Portageville, MO
Floyd G. Trammell – Greenpoint Ag - Greenville, MS
Gary Brent Hansen – Nutrien, Inc - Perry, UT
Janet Doan – Gavilon Grain, LLC - Omaha, NE
Keith A. Kennedy – Agrimind LLC - Laramie, WY
Maria Schoen – The Andersons, Inc. - Sioux City, IA
Mike Keene – Southern States - Bear, DE
Robin Studney – Gavilon Fertilizer - Saginaw, TX
William Weis – Nutrien - Cleveland, MO

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More Facilities Earn ResponsibleAg Certification

Welcome to these facilities that are now Committed, Compliant, Safe, and Certified. Congratulations to all! To date, more than 2,750 locations have achieved certification. Great work everyone!

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OUR MISSION

ResponsibleAg is an industry-led initiative committed to helping agribusinesses properly store and handle farm input supplies. The program helps members ensure they are compliant with environmental, health, safety and security regulations to keep employees, customers and our communities safe.