Worker safety and OSHA recordkeeping

Definition

Worker safety on a dairy covers the hazards of the work and the program that controls them: written safety policies, hazard-specific training, personal protective equipment (PPE), and injury and illness records.

Main dairy hazards:

Animal handling: kicks, crushing, being pinned in alleys, chutes and pens; bulls.
Machinery and vehicles: tractors (rollover), skid steers, feed mixers, PTO shafts and other unguarded moving parts.
Manure storage and confined spaces: hydrogen sulfide and other manure gases, drowning in lagoons or pits.
Chemicals: teat dips, CIP detergents and acids, drugs and needles (accidental self-injection).
Heat stress, slips and falls in parlors, noise, and zoonoses.

OSHA (29 CFR Part 1904) sets the injury and illness recordkeeping rules:

Form 300: the log of work-related injuries and illnesses that meet the recording criteria (beyond first aid, days away, restricted work, medical treatment, loss of consciousness, or a significant diagnosed injury).
Form 301: the incident report for each recordable case. Each case goes on the 300 log and a 301 within 7 calendar days of learning of it (29 CFR 1904.29).
Form 300A: the annual summary, certified by a company executive and posted in the workplace from February 1 to April 30 of the following year (29 CFR 1904.32).
Severe-injury reporting: report a work-related fatality to OSHA within 8 hours, and an in-patient hospitalization, amputation or loss of an eye within 24 hours (29 CFR 1904.39), by phone to the area office or 1-800-321-6742, or online at osha.gov.

Other OSHA rules that apply on farms include the agriculture standards in 29 CFR Part 1928 (rollover protective structures, guarding of farm equipment, field sanitation), Hazard Communication (29 CFR 1910.1200) for chemicals, and the General Duty Clause (OSH Act section 5(a)(1)).

Small-farm enforcement limits: a long-standing rider in the annual federal appropriations act bars federal OSHA from spending funds to enforce on farming operations with 10 or fewer employees that have no active temporary labor camp and have had none in the previous 12 months. Immediate family members of the farm employer are not counted. The rider remains in force as of Nov 2026: OSHA’s enforcement-exemptions page cites the Appropriations Act for 2026, and the current directive is CPL 02-00-170 (July 18, 2024). OSHA’s 2014 small-farm memo treats some post-harvest activities on small farms as outside the exemption; members of Congress have disputed that reading.

Separately, a company with 10 or fewer employees at all times during the last calendar year (peak employment, counted across the whole company) is partially exempt from keeping the 300/301 forms (29 CFR 1904.1), but must still report severe injuries under 1904.39. State-plan states run their own OSHA programs.

How to pull it in DC305

Not in DC305. Evidence lives in:

the OSHA 300 log, 301 reports and 300A summaries (paper or electronic);
the written safety program and hazard-specific SOPs;
training records (topic, date, trainer, language, signature): see SOPs and training records;
workers’ compensation claims and first-aid logs;
HR or payroll systems for employee counts (which decide the exemptions above).

Typical range

Herd context: US dairies with hired labor; federal OSHA rules as of 2026. State-plan states differ.

Retention: keep the 300 log, 300A summaries and 301 reports for 5 years after the end of the calendar year they cover (29 CFR 1904.33).
Electronic submission (29 CFR 1904.41): establishments with 20–249 employees in Appendix A industries (all of NAICS 11, agriculture) and all establishments with 250+ employees must submit Form 300A data each year, due March 2. Establishments with 100+ employees in Appendix B industries must also submit 300 and 301 data; Appendix B includes NAICS 1121, cattle ranching and farming, which covers dairies. Part-time, seasonal and temporary workers each count as one employee.
Training: hazard-specific training at hire and when duties change; many farms run refresher safety training at least annually and keep sign-in sheets.
Injury rates: BLS 2024 rates per 100 full-time workers for dairy cattle and milk production (NAICS 11212) were 3.2 total recordable cases and 2.4 days-away, restricted or transferred (DART), against 3.9 and 2.5 for all of agriculture, forestry, fishing and hunting and 2.3 and 1.4 for all private industry. Compare a farm’s recordable rate (cases × 200,000 ÷ hours worked) with the BLS rate for its industry code.

Requirements change; confirm the current version with the program or regulator. This page is not legal advice.

Common mistakes

Assuming the farm is exempt without checking the employee count, labor housing, or whether the state runs its own plan.
Confusing the recordkeeping exemption with the enforcement limit. They are separate rules, and neither removes severe-injury reporting.
Not posting the 300A, or posting it unsigned.
Logging only lost-time injuries: medical-treatment and restricted-work cases are also recordable.
No manure-storage or confined-space rules: entering pits or tanks without gas testing or a rescue plan.
Unguarded PTOs and mixers, and tractors without rollover protection.
Training not documented, or given only in a language some workers don’t read.
Needle-stick and chemical exposure not treated as recordable when they require medical treatment.