Newsletter

Volume 34

 

Mar 10, 2020

Top 25 Common Audit Issues Compiled

Each year, ResponsibleAg tallies the occurrence of compliance issues found during ResponsibleAg audits. The list of 2019 Top 25 Audit Issues is online now. It is a handy reference tool and starting point for retail location managers and health, safety and environmental staff. The list is just one resource from ResponsibleAg to help ensure facilities are compliant with environmental, health and safety regulations to keep employees, customers and local communities safe.

The order has changed some from 2018! Safety Shower/Eye Wash Maintenance jumped from #10 to #7 and First Aid Kit moved up four spots from #18 to #12. Click the Top 25 icon at the upper right on the ResponsibleAg website to learn more. Would your company’s facilities comply with these 25 issues? Knowing potential issues and having guidance to correct them are benefits of being a member of ResponsibleAg. Register today!

June Auditor Training Course Will Be Here Soon – Register Today!

If you are considering becoming a ResponsibleAg credentialed auditor, register today for the June 16-19 course in Owensboro, KY. The comprehensive, four-day, ‘hands-on’ course is held in a former agrichemical facility retrofitted specifically for training purposes, and the course takes a very practical approach to training industry professionals about compliance issues and the audit process. To learn more about becoming a credentialed auditor, visit the Become an Auditor section on ResponsibleAg.org.

Congratulations to Rosemary O’Brien on Upcoming Retirement

Rosemary O’Brien, Vice President of Public Affairs at CF Industries Holdings, Inc., is a long-time champion for safety at CF Industries and throughout the entire industry. Thank you, Rosemary, for your dedication to this vital endeavor, and especially for serving on the ResponsibleAg Board of Directors since the initiative began in 2014. Congratulations on your well-earned retirement. ResponsibleAg and the entire industry will miss you!

Valley Agronomics Moves Quickly to a Safe and Compliant Future; Completes 23 ResponsibleAg Audits in 3 Months

When the Valley Ag leadership team members turned their focus to enhancing the organization’s employee safety and regulatory compliance practices, they chose the ResponsibleAg Certification Program. The company dove in headfirst, completing ResponsibleAg audits at 23 locations in three months. Read more about how employees at the company are working together to develop and implement safety policies and practices across the organization and how they use ResponsibleAg audits as the basis for identify areas for improvement.

Showcasing Agriculture and Sustainability during National Ag Day and Ag On the Mall

ResponsibleAg salutes individuals and organizations throughout the industry who work to educate legislators and the public about modern agriculture and the industry’s sustainability efforts in the production of food and fiber. Our industry is working hard to increase food production while shrinking its environmental footprint.

Celebrate National Ag Day on March 24th, and be sure to share how you, your customers and the industry work to provide a plentiful and safe supply of food and fiber. In conjunction with National Ag Day, the Celebration of Agriculture on the National Mall takes place March 23-24 in Washington, DC. Hosted by the Association of Equipment Manufacturers and supported by The Fertilizer Institute, Agricultural Retailers Association and others, the event includes a large display of the latest agricultural equipment and information about the sustainability benefits of modern agriculture. There will also be an on-site charitable volunteer opportunity to pack meals for the hungry.

Audit Issues Awareness – A New #7 Safety Shower/Eye Wash Maintenance

Number 7 on the ResponsibleAg list of Top 25 Audit Issues is Safety Shower/Eye Wash Maintenance. This requires the facility to have records indicating the shower/eye wash have been activated at least weekly and inspected annually.

For more information about these and other regulations and documentation, join ResponsibleAg. Program 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.

Not a Member of ResponsibleAg? Have Questions About Participating?

If you’ve thought about participating in the ResponsibleAg program but have questions about the organization and its mission, you may find answers in the most frequently asked questions. Don’t just take our word for the benefits of becoming a member of the organization ‒ read why many of your industry peers have made a commitment to ResponsibleAg in these Faces of ResponsibleAg articles.

Respirator Demand Surges due to Coronavirus; 8-10 Week Lead Time

Fear of the coronavirus is causing a worldwide shortage of disposable respirators and a backorder of many reusables. Manufacturers report extended lead times on most respirator supplies while supplier stocks continue to deplete. This comes at a time when respirator usage is high in the agricultural industry. Take steps now to try to secure respirators you may need for the season. Read this recent 3M announcement.

National Ladder Safety Month Is February 23rd - March 31st

More than 100 people die each year in ladder-related accidents, and thousands suffer disabling injuries. March 2020 marks the fourth annual National Ladder Safety Month, which is the only movement dedicated exclusively to the promotion of ladder safety at home and at work. Goals of National Ladder Safety Month include:

• Lowering the rankings of ladder-related safety citations on OSHA’s yearly “Top 10 Citations List”
• Increasing the number of companies and individuals that inspect and properly dispose of old, damaged or obsolete ladders
• Decreasing the number of ladder-related injuries and fatalities

Learn more about National Ladder Safety Month.

April is Distracted Driving Awareness Month

Everyone in agriculture is gearing up for the busy spring season. It’s time to emphasize the importance of safe driving to everyone in your organization. About 40,000 people were killed in motor vehicle accidents in 2018 (do we not have the 2019 number?). Modern advances ‒ from cell phones to dashboard infotainment systems to evolving voice-command features ‒ all pose a threat to personal safety. It just takes one second of distraction to change a life forever. Share these interesting facts with your team:

• 94% of crashes are caused by driver error
• 7% of all drivers at any given time are using their phones while driving. A NHTSA survey found 660,000 drivers using cell phones or manipulating electronic devices while driving at any given daylight moment
• Drivers talking on phones, hand-held or hands-free, miss seeing up to 50% of what is around them, such as other drivers, pedestrians and bicyclists

These statistics are among the reasons dozens of Fortune 500 companies have adopted cell phone policies, banning the use of phones while driving. Learn more about this safety initiative.

Be Safe This Spring! Check Your Inbox in June for Our Next Newsletter

ResponsibleAg wishes everyone a safe spring planting season. Whether spring work has already begun in your area or you won’t be in the fields for another month, be safe during this busy time of year. The ResponsibleAg newsletter will take a two-month hiatus, but make sure to check your inbox in June for the next issue. News from Around the Industry

Entry-Level Driver Training Compliance Deadline Extended

The U.S. DOT Federal Motor Carrier Safety Administration (FMCSA) recently extended the compliance date for the Minimum Training Requirements for Entry-Level Commercial Motor Vehicle Operators from Feb. 7, 2020, to Feb. 7, 2022. This extension gives FMCSA additional time to complete development of the Training Provider Registry. Learn more here.

DOT Cautions Drivers about CBD Products

The U.S. DOT recently issued a compliance notice warning drivers and other safety-sensitive workers about the potential mislabeling of hemp-derived products. These products could contain illegal levels of tetrahydrocannabinol (THC) that might result in a positive DOT drug test. The FDA doesn’t currently certify the levels of THC in CBD products, so there is no Federal oversight to ensure label accuracy.

It remains unacceptable for any safety-sensitive employee subject to DOT’s drug testing regulations to use marijuana. CBD use is not a legitimate medical explanation for a laboratory-confirmed marijuana positive result. Medical review officers will verify a drug test as positive if it is confirmed at the appropriate cutoffs, even if an employee claims to have used only a CBD product. Since the use of CBD products could lead to a positive drug test result, DOT-regulated safety-sensitive employees should exercise extreme caution when considering using CBD products.

DOT Cautions Drivers about CBD Products

The U.S. DOT recently issued a compliance notice warning drivers and other safety-sensitive workers about the potential mislabeling of hemp-derived products. These products could contain illegal levels of tetrahydrocannabinol (THC) that might result in a positive DOT drug test. The FDA doesn’t currently certify the levels of THC in CBD products, so there is no Federal oversight to ensure label accuracy.

It remains unacceptable for any safety-sensitive employee subject to DOT’s drug testing regulations to use marijuana. CBD use is not a legitimate medical explanation for a laboratory-confirmed marijuana positive result. Medical review officers will verify a drug test as positive if it is confirmed at the appropriate cutoffs, even if an employee claims to have used only a CBD product. Since the use of CBD products could lead to a positive drug test result, DOT-regulated safety-sensitive employees should exercise extreme caution when considering using CBD products.

Accidental Release Reporting Rule Finalized – Add CSB to the List

The U.S. Chemical Safety and Hazard Investigation Board (CSB) recently approved a final rule on accidental release reporting. The rule requires prompt reports to the CSB from owners/operators of facilities that experience an accidental release of an extremely hazardous or regulated substance that results in a death, serious injury or substantial property damage. The rule is required by the CSB’s enabling legislation but was not issued during the first 20 years of CSB operations. Last year, a court ordered the CSB to finalize a rule within a year.

Submitting a report to the National Response Center (NRC) under other laws does not satisfy the CSB’s reporting requirement. However, the requirement can be satisfied by submitting the NRC identification number to the CSB within 30 minutes of submitting a report to the NRC. Get full details here.

OSHA Penalties Adjusted for Inflation

The maximum penalty amounts that OSHA can assess have been adjusted for inflation, effective January 15th. The 2020 numbers include a cost-of-living adjustment multiplier based on the Consumer Price Index, which was calculated at 1.101764 as of October 2019. The most recent penalty amount for each level of violation was multiplied by this number and then rounded to the nearest dollar. The maximum penalty for serious violations will rise to $13,494 per violation. The maximum penalty for willful or repeated violations will increase to $134,937 per violation.

Chemical Facility Anti-Terrorism Standards Scheduled to Expire April 18th ‒ Contact Congress Today

The U.S. Chemical Facility Anti-Terrorism Standards (CFATS) program is in jeopardy of expiring on April 18th unless Congress takes action. The CFATS program is one of the primary federal security programs for chemical facilities and gives the Department of Homeland Security the authority to regulate security at thousands of facilities across the country. The program has made great strides in helping to enhance chemical security; to date it has completed more than 4,000 authorization inspections and almost 6,000 compliance inspections. Learn more and send a message to Congress today.

EPA Reaches Settlement with Kansas Company

A Kansas company recently agreed to pay a civil penalty of $71,652 and return three facilities to compliance after two 2018 EPA inspections found each facility had more than 10,000 pounds of anhydrous ammonia, making them subject to Risk Management Program regulations. During the inspections, EPA found that the company failed to submit, implement and update risk management plans for the release of anhydrous ammonia; failed to ensure that the facilities’ processes for handling anhydrous ammonia were designed in compliance with good engineering practices; failed to perform required tests and inspect processing equipment at the facilities; and failed to update required documentation.

In addition to achieving regulatory compliance, the company agreed to enhance safety at six of its ammonia fertilizer facilities by installing emergency shutoff valves and emergency stop buttons. The company estimates the project will cost at least $55,000.

Celebrating Facilities Earning ResponsibleAg Certification and Recertification

Welcome to the facilities that have completed their Corrective Action Plans and are now Committed, Compliant, Safe, and Certified.

We'd also like to send a special Shout Out to the locations noted below with an asterisk*. They have completed Recertification. This commitment to safety is a great example for all! Congratulations!

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.