Have you had a full headquarters inspection in the recent years? If not, you are more than likely overdo and may be contacted by your county Ag Commissioner’s office. We have had several of our growers receive full headquarter inspections over the past couple of months and as such, thought it would be good idea to discuss the subject.
So what exactly is a headquarters inspection? Well, simply put, it is an inspection by a county official or a DPR agent of the documentations, postings and storage areas found at your operation. Understanding this, you may be asking yourself, what is it that triggers an inspection? It turns out that there are really 3 main circumstances that would prompt the county to conduct an inspection at your operation. The first would occur if a county official, while observing your field operations, found one or more violations. The second would be if an investigation was being done by the Ag Commissioners office due to a compliant they received. This could have been in the form of a neighbor filing a complaint after observing something they considered alarming, or a motorist whose vehicle was drifted on while driving down the road. The third and final situation to cause an inspection would be if the Ag Commissioner’s office was conducting their biannual inspections. Understanding the things that cause a headquarters inspection, now let’s take a look at the specific items an inspector will be looking at.
The components that you will need in order to pass an inspection can be broken down into 4 sections. The first is your documentation and training. The second are the respirator requirements that you need to meet. The third are all of the postings that you are required to have on site, and the forth is your pesticide storage area. Let’s break down each of these, one at a time, and discuss them in more detail.
When it comes to your documentation and training, you will need to be sure that you have the following:
– Valid Pesticide Permit (for the last 2 years)
– Written Disciplinary Action Policy
– Written training program
– Pesticide Training Records (for the last 2 years)
– Fieldworker Training Records (for the last 5 years)
– Notification Prior to Application (NOI records)
– Application Completion Records (use reports)
– Organophosphates/Carbamate Records
– MSDS Sheets (Material Safety Data Sheets)
Hopefully, you already have all of these components on your operation and are good to go. If not, however, please feel free to contact us. We will be more than happy to get you up to speed.
The respirator requirements that you will need to meet are a bit less intensive than your documentation, but equally as important. These requirements are as follows:
– Written Medical Clearance Forms (for employees who use respirators)
– Annual Fit Testing Documented
– Annual Training Documented
– Annual Review Documented
– Written Respirator Program
If you have any questions about the above respirator requirements, please feel free to contact me.
Posting requirements refer to the postings that you must have at a common place, or where workers regularly gather, on your operation. The following forms are required:
– Voluntary Respirator Form
– Hazardous Communication/Handler A-8
– Hazardous Communication/Fieldworker A-9
– Emergency Medical Care Information (location of closest hospital & contact information)
The last items essential to successfully passing a headquarters inspection are being sure that you are properly storing both your personal protective equipment (ppe) and your pesticides. When it comes to ppe storage, be sure that all equipment is stored away from any pesticides. In other words, do not store your ppe in your pesticide storage area. You must also be sure that all respirators are properly stored in plastic zip lock bags, as a way to further reduce the risk of contamination. Lastly, you should conduct regular inspections of all respirators. It doesn’t hurt to do this before every use and make sure that you document these inspections.
Your pesticides should be stored in a locked structure. This can be an enclosed area, such as a shed or shipping container, or a chain linked fence. If you choose to use a fence, it must be at least six feet high. No matter what type of structure you use, you will need to label them all with the proper warning signs, indicating that they are pesticide storage areas. Along with these requirements, it is important to remember that you should never use anything other than a pesticide container, such as a food container or water bottle, to store pesticides in.
We hope that you have found this information to be useful and that you feel better prepared to successfully pass a headquarters inspection. If, however, you find that you have more questions, or need help getting your operation up to par, please feel free to contact us. We are here to make sure that you and your operation continue to be successful well into the future.
Ryan Genzoli
Cal Ag Safety
209-401-4802
rgenzoli@calagsafety.com
The Cal Ag Safety Blog 