By Sarah Gonzalez, Director of Communications and Digital Media
The 2016 Safety and Grain Quality Conference, hosted by NGFA and Grain Journal, attracted more than 280 facility managers, employees and industry experts to Omaha, Neb., where they participated in mock Occupational Safety and Health Administration (OSHA) inspections, learned about the latest regulatory requirements and brushed up on best practices for maintaining grain quality and safety standards.
The conference included almost 60 exhibitors and expert speakers from the industry, law and government, as well as ample networking opportunities. The day-and-a-half conference included several breakout sessions in addition to keynote speakers. All presentations are available on the Safety and Grain Quality Conference website below each session name.
During the conference, NGFA Chairman John Heck, who is senior vice president of The Scoular Company, welcomed attendees to Omaha, after which Nick Friant, the food safety, quality and regulatory leader at Cargill, provided an overview of best practices to implement at grain facilities while recognizing the connection between grain quality and safety. Friant summarized his main points in this video.
Eric Conn, chair of the OSHA Practice Group at Conn Maciel Carey PLLC in Washington D.C., provided a thorough overview of the most important aspects of an OSHA inspection. He noted that the opening conference of an OSHA inspection is the most important part of the entire process, as it’s the last chance to stop an erroneous inspection before it begins.
Conn also emphasized the importance of recordkeeping as it relates to regulatory matters. “Make a duplicate set of everything you give to OSHA,” he said, adding that maintaining a document control log will go a long way to making the process run as smoothly as possible. He reviewed several key highlights of the session in this video.
During the same session, Doug Fletcher, president of Fletcher Safety Consulting, Inc. in Omaha, Neb., and former OSHA inspector, reminded attendees that their employees’ inspection rights are the primary concern for the OSHA inspector.
“Employees have right to see the outcome of inspection,” he noted, adding the facility managers must post notifications about an inspection and “employees must be apprised of all the steps throughout the process.”
Conn noted that employees’ rights also extend to private interviews with OSHA inspectors, and that “the law is clear that if you have a subpoena, the witness can have any representative he wants with him in the interview.”
NGFA Vice President of Safety and Regulatory Affairs Jess McCluer provided a general session presentation on OSHA’s latest regulatory updates. He reminded attendees that OSHA civil penalty fines have officially increased almost 80 percent. The penalty increase, which became effective Aug. 1, is in response to the Federal Civil Penalties Adjustment Improvements Act of 2015, which was part of last year’s budget bill. The rule allows OSHA to fine employers at new levels for all citations issued after Aug. 1, even where the alleged violation predates the rule’s effective date. Any violation occurring six months prior to Aug. 1, and cited on or after Aug. 1 will be subject to the new higher penalties. Read more about the increase here.
NGFA Senior Vice President of Feed Services Dave Fairfield ended the conference with an overview of new rules the U.S. Food and Drug Administration is implementing under the Food Safety Modernization Act (FSMA). Fairfield is conducting regional seminars about the new regulations across the country, as well as serving as chair of the Animal Food Subcommittee of the Food Safety Preventive Controls Alliance (FSPCA), which developed curriculum for the Preventive Controls for Animal Food Course. To learn more about the seminars and other FSMA training opportunities, go to www.www.ngfa.org.
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