Occupational Safety and Health Administration
Feline exhibitors are familiar with the USDA and the need to follow the Animal Welfare Act regulations. Failure to maintain a safe and healthy environment for your animals can lead to citations, and if infractions are repeated, even fines, as much as $10,000 per infraction can be levied. Now that doesn’t happen very often, thank goodness.
Animal Care inspectors look at your operations, and size you up. They cite you when you fail to meet minimum standards, and they give you a timetable to correct the problem. If you do make corrections, you most likely will not face any penalties. Infractions are divided into direct, and indirect. Direct infractions involve the animals, and indirect (like recordkeeping) are less serious because they do not put the animal’s health and safety at risk.
But there is another government agency that commercial exhibitors and breeding facilities may not realize also has authority over their operations. Unlike USDA, which issues the license to do business and inspects periodically, OSHA, the Occupational Safety and Health Administration, also has enforcement powers over employers. But this agency focuses on job injuries, illnesses and deaths of the employees, not the animals.
If you have just a single employee, you must follow OSHA standards. There are 22 states that have developed their own safety and health programs, the other 28 states are regulated by the federal agency. A small exhibitor or breeder may never see an OSHA inspector, but if there is an accident, or a complaint, they may find themselves dealing with this “other” government agency and its many regulations. Employers are required to report to OSHA within eight hours, any fatal accident, or injury that results in the hospitalization of three or more employees.
The federal government has a vested interest in helping businesses protect their workers and reduce the number of workplace deaths, injuries and illnesses. When employees stay safe and healthy, there is less government payout on workers’ compensation insurance costs and medical expenses.
In general, OSHA “standards” require employers to maintain conditions to protect workers on the job. Employers need to be familiar with and comply with standards applicable to their establishments. Employers must ensure that employees have and use personal protective equipment when required for safety and health. The OSHA Act’s “general duty clause” requires that each employer furnish a place of employment free from recognized hazards that are likely to cause death or serious physical harm to employees.
Now in the big cat world, we all know that working with lions, tigers, leopards and other feline predators carries with it an inherent risk of injury. But where are the specific OSHA regulations on cats? OSHA will refer to the USDA regulations ad your inspection reports. For instance, if you are cited by the USDA for failing to maintain enclosures in good repair, and an employee is injured by an animal, OSHA is going to fine you for a workplace safety violation, even if USDA does not.
Here are some things to consider when developing a safety program at your workplace.
Safety Program Development – Set up a safety program and make sure your team buys into it.
Accident Investigations – Deal with an accident after the fact and prevent similar accidents from occurring again.
Emergency Planning – Plan for the unexpected. Teach your employees how to handle any emergency situation that may appear.
Safety Audits – Regularly review your workplace, equipment, tools, and materials to ensure all hazards are being addressed.
OSHA is concerned about record keeping. While you know your employees, and their qualifications, if it is not documented, then it is not going to be accepted by OSHA. Maintain a written record of each employee’s experience, both prior to hiring and while in your employment. If it’s not written down, it didn’t happen according to OSHA. If you send your employees to continuing education seminars, document it. If you have a period of time where new employees are trained by more experienced personnel, write it down. No records and you will be cited for having employees that lack training. Start instituting daily logs and you will be way ahead if OSHA ever pays your business a visit.
It’s not just the cats we have to worry about. . . .
Blood Borne Pathogens - We all know that preparing cat food causes more injuries than any other aspect of cat husbandry. A lot of time is spent using sharp knives, axes, cleavers and meat grinders. These are recognized employee hazards. Ever been to a chicken processing plant? The employees wear protective chainmail gloves to prevent being cut. If your facility processes animals for feeding, then your employees are exposed to blood, feces, and biological hazards. Employees need protective clothing – full body aprons, boots and hand protectors, even eye protectors could be required if butchering large animals with power tools. Does your facility compost its feline poop, bedding, and the guts of animals being fed? These are considered “biological hazards” by OSHA and this agency will want employees that work with this matter to be issued protective foot covering.
Hazardous Materials – Have you ever noticed how manufacturing businesses have these material safety data sheets prominently posted on the walls informing employees of what chemicals they may be exposed to and how to react to unintentional exposure? Same holds for animal facilities. Do you use chlorine bleach or other disinfectants? What about pesticides to keep down ticks and fleas, or and herbicides to maintain property landscaping? If you are hiring employees to spread these products, you need to have safety sheets available for employees to see. Your employees and site visitors must be made aware of the hazardous materials in your workplace and understand how to protect themselves from these hazards.
How do you make sure your facilities are safe for your employees and visitors?
OSHA will rely heavily on USDA regulations on caging. If you have been cited by USDA and OSHA finds out, while USDA may not fine you for the infraction, OSHA will. Keep your cages in good repair, your fencing in compliance with USDA standards, and your public barriers of proper height, strength, and material construction.
OSHA has regulations for tools and equipment, for personal protection, for workplace safety, even behavior and attitude. OSHA will investigate how you address the behaviors of employees and workplace visitors that may have an adverse effect on the safety and health of your team. OHSA wants to know how your organization deals with conflict, drugs, fitness, safety housekeeping, and workplace stress and violence.
What must animal facility employers do to comply with OSHA?
Employers are required to keep the workplace free from serious recognized hazards and monitor workplace conditions to make sure they conform to OSHA standards. Here are ten rules to live by:
1. Keep tools and equipment properly maintained prior to employee use. 2. Identify hazards for your employees by using color codes, posters, labels and signs. 3. Develop/maintain safe operating procedures and train employees to follow the requirements. 4. Post the OSHA Poster (or the state-plan equivalent) informing employees of their rights and responsibilities at a prominent location within the workplace. 5. Report any fatal accident or one that results in the hospitalization of three or more employees to the nearest OSHA office within 8 hours. 6. Keep records of work-related injuries and illnesses and allow employees and former employees to access the OSHA Log of Work-Related Injuries and Illnesses (OSHA Form 300). 7. Provide employee medical & exposure records to employees or their authorized representatives upon their request. 8. Identify authorized employee representatives who may be asked to accompany the OSHA compliance officer during an inspection. 9. Do not discriminate against employees who exercise their rights under the Act. Post OSHA citations at or near the work area involved until the violation has been corrected, or for three working days, whichever is longer. 10. Correct violations by the deadline set in the OSHA citation and submit required verification documentation.
Useful Resource for Safety in the Workplace
Floor Marking is one way to make facilities more efficient and safer. Here is a comprehensive page on the internet about Floor Marking. It has everything an organization needs to implement a floor marking system, to make themselves safer, more efficient and profitable.
Learn More About OSHA
If your business has never thought about OSHA, it is overdue. Workplace safety is part of any professional operation and the government has set up an agency and standards to help ensure that accidents do not happen. You can read more about this at www.OSHA.gov. You can also request a courtesy visit to review of your business without risk of being fined.