Agricultural Safety & Health
Research, Outreach, and Education to improve the health, safety, and well-being of agriculture

OSHA WI Dairy Farm LEP Guidance Documents

The following information relates to the OSHA directive CPL 04-00 (LEP 009) for Wisconsin Dairy Farms. This information is intended to help direct individuals to the sources of the guidance documents. In some cases notes have been added to address materials that have been updated or revised from those referenced in the original LEP.

Note: The Wisconsin OSHA Dairy LEP has expired and was not renewed for 2017-2018. These documents are still good guidance for developing safety programs on dairy farms.

From: Directive Number: CPL 04-00 (LEP 009)

  • Effective date: October 1, 2016
  • Expiration date: September 30, 2017
  • A PDF of the complete 2016-2017 OSHA Dairy LEP can be found here.
  • A PDF of 2016-17 Quick Glance at the OSHA Dairy Farm Local Emphasis Program can be found here.

I. Purpose.

The purpose of this Notice is to continue a Local Emphasis Program (LEP) for programmed inspections of establishments within the dairy farming industry having operations classified as dairy cattle and milk production under the North American Industry Classification System (NAICS) code 112120, in accordance with the provisions of OSHA Instruction Number CPL 04-00-001, Procedures for Approval of Local Emphasis Programs (LEPs).

Note: Unprogrammed activities (i.e., accidents, complaints, referrals, fatalities/catastrophes) conducted in dairy heifer replacement production facilities categorized under NAICS code 112111 should be inspected in accordance with the guidance in this LEP and should be coded concurrent with Section X of this document. Dairy heifer replacement production facilities are not being programmed for inspections under the scope of this LEP.

VII. Action.

The Appleton, Eau Claire, and Madison Wisconsin OSHA Area Offices shall use the LEP described herein as the basis for scheduling programmed inspections to reduce occupational hazard exposure in the dairy farming industry. The Milwaukee, Wisconsin OSHA Area Office shall use the LEP described herein for conducting unprogrammed activities (i.e. accidents, complaint, referrals and fatalities/catastrophes).

VIII. Program Procedures.

C. A cycle size of four establishments will be used. Once a cycle is begun, it must be finished. One establishment will be randomly selected from List #1. Three establishments will be randomly selected from List #2.

Establishment sources:
  • List #1 – WI Department of Agriculture, Trade and Consumer Protection (DATCP) licensed milk producers listing—approximately 13,000 Grade A and B milk producers in Wisconsin.
  • List #2 – WI Concentrated Animal Feeding Operations (CAFO) water protection permit listing—approximately 150 farms with more than 700 dairy cows in Wisconsin.

This LEP is being implemented to direct OSHA’s field inspection efforts to address the following common hazardous activities found throughout dairy farm operations:

1. Manure Storage Facilities and Collection Structures:

Fatal or serious drowning hazards may exist where farm vehicles such as tractors, manure spreading trucks, manure pumps/agitators, and skid-steers are operated in near proximity to waste storage impoundments and structures without the benefit of control measures, such as 1) safety stops and/or gates at manure push-off ramps and load-out areas to prevent accidental entry of machinery;and 2) warning signs, fences, ladders, ropes, bars, rails and other devices to restrict the accidental passage of vehicles and personnel across outdoor earthen manure storage.

Fatal or serious inhalation hazards of gases including hydrogen sulfide (H2S), carbon dioxide (CO2), methane (CH4), and ammonia (NH3) may exist where manure gases are generated through the handling of liquid or semi-solid manure through activities such as pumping, mixing, agitating, spreading, or cleaning-out. Oxygen (02) deficiency hazards are an additional related concern.

Guidance Documents:
  • American Society of Agricultural and Biological Engineers (ASABE) Standard – ASAE EP470 JAN1992 (R2005) Manure Storage Safety available here.
  • Wisconsin Natural Resources Conservation Service (NRCS) Conservation Practice Standard – Waste Storage Facility Code 313
  • Division of Cooperative Extension of the University of Wisconsin-Extension: “Safety Considerations for Manure Handling, A3675”
  • The University of Maine Cooperative Extension, Maine Farm Safety Program: “Barn and Manure Storage Safety, Bulletin 2304”
  • Texas Cooperative Extension, The Texas A&M University System:“Manure Pit Safety”
  • Iowa State University Extension: “Manure Storage Poses Invisible Risks, Pm-1518k (1993)”
  • National Institute for Occupational Safety and Health (NIOSH):“NIOSH ALERT on Manure Pits, DHHS (NIOSH) 90-103”

2. Animal Handling/Worker Positioning/Needlestick Prevention:

Fatal or serious crushed-by hazards may exist where employees interact with dairy bulls and cows without appropriate training on appropriate animal handling techniques, especially in areas where there is an increased likelihood of becoming caught between the animals and a fixed or moving structure such as a fence, corral, opening gate, crowd gate, etc. Serious contact hazards may also exist where animals are handled for the purposes of medical procedures and artificial insemination and are not properly restrained.

Potentially serious needlestick hazards may exist where farm workers or veterinarians utilize needles to administer medications (vaccinations, sedatives, etc.) to animals that are not properly restrained. Common injuries may include skin infections, tissue wounds, and allergic reactions. Although less common, the potential for serious side effects from vaccinations and sedatives exists.

 Guidance Documents:

 3. Electrical systems:

Electrocution and electrical shock hazards may exist where employees interact either: 1) making direct contact with improperly installed, improperly maintained, or damaged electrical systems on equipment such as disconnects, switches, circuit-breakers, pumps, fans, augers, fences, etc.; or 2) making indirect contact with overhead or buried power lines with farm equipment such as tractors, skid steers implements, portable augers, grain probes, ladders, poles, rods, irrigation pipes, etc.

 Guidance Documents:

4. Skid-Steer Loader Operation:

Fatal or serious crushed-by, struck-by, caught in-between, and/or rollover hazards may exist where employees are:

  1. Improperly trained on operating, servicing, or maintaining skid-steer loaders according to the manufacturer’s instructions
  2. Failure to use approved lift arm support devices when servicing or maintaining the skid-steer loader
  3. Intentional bypassing of safety features of the skid-steer loader such as back-up alarms, seat belts, and control interlock systems.
 Guidance Documents:
  • Manufacturer’s skid-steer loader operator manual and instructions
  • The Association of Equipment Manufacturers (AEM) Safety – Manual for Operating and Maintenance Personnel,Skid-Steer (2006)
  • Division of Cooperative Extension of the University of Wisconsin-Extension and other States’ Cooperative Extension Program documents and training materials
  • OSHA Safety and Health Information Bulletin (SHIB) “Hazards Associated with Operating Skid-Steer Loaders with Bypassed and/or Improperly Maintained Safety Devices, SHIB 01-12-2009”
  • National Institute for Occupational Safety and Health (NIOSH): “NIOSH ALERT on Preventing Injuries and Deaths from Skid-Steer Loaders, DHHS (NIOSH) 98-117”
  • Division of Cooperative Extension of the University of Wisconsin-Extension: “Safe Use of Skid-Steer Loaders on the Farm, A3674”
  • Kansas State University Research and Extension: “Skid Steer Loader Safety for the Landscaping and Horticultural Services Industry”

5. Tractor Operation:

Fatal or serious fall, struck-by, caught in-between, and/or rollover hazards may exist where employees are improperly trained on operating, servicing, or maintaining tractors.

Regulatory information:
Guidance Documents:
  • Association of Equipment Manufacturers (AEM) Safety – Manual for Operating and Maintenance Personnel, Agricultural Tractor (2005)
  • Iowa State University Extension: “Employers’ Instructional Guide, Training Employees Who Operate Agricultural Tractors, Pm-632 (r2000)”
  • University of Missouri Extension: “Safety Tractor Operation (2002)”

6. Guarding of Power Take-Offs (PTOs):

Fatal or serious entanglement and/or amputation hazards may exist where power take-off shafts and other related components on farm field and farmstead equipment are not properly guarded.

Regulatory information for farm field equipment:
Regulatory information for farmstead equipment:

7. Guarding of other power transmission and functional components:

Fatal or serious entanglement and/or amputation hazards may exist where other power transmission components on farm field and farmstead equipment are not properly guarded.

Regulatory information for farm field equipment:
Regulatory information for farmstead equipment:

8. Hazardous energy control while performing servicing and maintenance on equipment:

Fatal or serious crushed-by, struck-by, caught in-between, amputation hazards may exist where employees perform maintenance and servicing on farm field, farmstead, or other equipment without a means of immediate and exclusive control of hazardous energy sources by the employee or the employees maintaining or servicing equipment.

Regulatory information for farm field and farmstead equipment:
Guidance documents:
Additional regulatory information for farmstead equipment:
Guidance documents for other equipment not meeting the definition of farm field or farmstead equipment:

9. Hazard communication:

Serious chemical ingestion, absorption, splash, fire, and/or other hazards may exist where hazardous chemicals such as teat dips, hoof care products, sanitation products, medications, sanitation products, etc. are stored, dispensed, and used without appropriate training and information including the availability of Safety Data Sheets (SDSs).

 Regulatory information:
Guidance Documents:
  • OSHA’s Hazard Communication web page
  • Upper Midwest Agricultural Safety and Health Center’s (UMASH) fact sheets: “Needlestick Prevention for Producers and Veterinarians” and “Needlestick Prevention on the Farm”

10. Confined Spaces:

Serious or fatal chemical asphyxiation, oxygen (O2) deficiency, inhalation, engulfment, and/or caught-in hazards may exist where there is entry into grain storage bins, boot pits, vertical silos, hoppers, manure storage vessels, milk vessels, below grade manure collection systems, etc.

 Guidance document:

11. Horizontal Bunker Silos:

Serious or fatal engulfment and/or struck-by hazards may exist where employees perform ‘facing’ activities when removing silage from ground level. Serious or fatal fall hazards may exist where employees climb on top of the silage to place or remove protective plastic covering and anchoring systems.

Guidance documents:
  • Division of Cooperative Extension of the University of Wisconsin-Extension and other States’ Cooperative Extension Program documents and training materials.
  • Penn State College of Agricultural Sciences Cooperative Extension: “Horizontal Silo Safety, E49” (2007)
  • University of Minnesota Department of Animal Science Dairy Initiatives Newsletter: “Safety in Silage Bunker Silos and Piles” Volume 10 Issue 1 (2001)

12. Noise:

Serious hearing loss hazards may exist when working with or around running agricultural equipment.

 Guidance documents:

Note: 29 CFR 1928.21(a)(1) – (7) incorporates 29 CFR 1910 standards: Temporary Labor Camps (1910.142); Storage and handling of anhydrous ammonia (1910.111(a) and (b))’; Logging 0perations (1910.266); Slow-moving vehicles (1910.145); Hazard Communication (1910.1200); Cadmium (1910.1027); Retention of DOT markings, placards, and labels (1910.1201). The remaining standards covered in Subpart B through T and Subpart Z of part 1910 do not apply to agricultural operations.