Listen to the audio version of this article. (Generated by A.I.)
For growers across California, Cal/OSHA compliance is more than just a legal requirement; it is an essential part of protecting your workforce and sustaining your business. Agriculture remains a priority industry for Cal/OSHA enforcement, and smaller employers are increasingly in the spotlight. Inspections are often triggered by accidents, worker complaints or targeted enforcement efforts, and the numbers show small operations are receiving a significant share of citations and penalties.
What the Data Shows
Between October 2023 and September 2024, Cal/OSHA issued hundreds of citations to California crop production operations under NAICS Code 111. The statistics tell an important story (Table 1).
The numbers make clear that smaller employers are not exempt from enforcement. In fact, employers with fewer than 20 workers paid $270,215 in penalties, more than the $237,865 paid by employers with over 250 employees. With margins already tight, a Cal/OSHA citation can create significant financial hardship, not to mention the operational disruption. Citations are not your only risk; repeat violations can escalate into expensive penalties, concerted activity complaints and PAGA claims.
For small and family-run operations, this trend should serve as a wake-up call. Being proactive about compliance can protect not only your bottom line but also the long-term sustainability of your operation.
Core Safety Programs Every Grower Needs
Compliance comes down to a handful of key written programs. These must be up to date, accessible and provided both in English and in the language your workforce understands. Failure to produce these programs during an inspection is one of the most common causes of citations.
Injury and Illness Prevention Program (IIPP)
The foundation of every safety system in California. A compliant IIPP identifies who manages the program, explains how safe practices are enforced, establishes two-way communication with employees, schedules regular inspections, documents investigations of accidents or exposures, requires timely hazard correction and ensures consistent worker training.
Heat Illness Prevention Plan (HIPP)
For outdoor work, the law requires employers to provide cool drinking water, access to shade, rest breaks and emergency response procedures. At 95 degrees and above, additional āhigh heatā procedures apply, including closer supervision and more frequent breaks. Plans must also address acclimatization for new workers.
Indoor Heat Illness Standards
Effective in 2024, these new rules apply to enclosed areas like packing sheds and kitchens. Employers must monitor the heat index, maintain cooldown areas at 82 degrees F or below, and provide 10-minute cooldown breaks every two hours once the temperature reaches 95 degrees F.
Workplace Violence Prevention Plan
As of July 1, 2024, all employers must maintain a written plan addressing workplace violence risks. The plan must include hazard assessments, employee reporting procedures, required training and an incident log that must be kept for five years. This can be integrated into your IIPP or kept as a standalone program.
Recommendations for Growers
Cal/OSHA provides template plans for IIPP, outdoor and indoor heat illness prevention, and workplace violence prevention directly on their website. These templates are a strong starting point and can save time and effort. However, it is critical to:
ā¢ Customize the templates with site-specific information that accurately reflects your operation.
ā¢ Ensure that activities listed in the plans are realistic and consistently implemented.
Having written programs is only one part of the puzzle. The true test of compliance occurs when Cal/OSHA arrives and begins an inspection. Inspectors will not only review your paperwork but also observe worksites, speak with employees and assess whether your daily practices align with your written plans. Understanding how inspections happen is essential to ensure your programs withstand real-world scrutiny.
What to Expect in a Cal/OSHA Inspection
Even well-prepared operations can feel uneasy when an inspector shows up. Knowing the process in advance can help reduce stress and ensure the best possible outcome.
Visitor arrival
Train supervisors, forepersons and crew leaders to politely welcome visitors and verify official identification. Investigators should be directed to the designated company contact, who will manage the inspection process.
The walk-around
An inspector will want to observe worksites, equipment and employee practices. Think carefully about the route you take. The company team should include a management representative, a safety or HR staff member, a photographer or note taker and, when relevant, a shop manager or mechanic to answer technical questions.
Employee interviews
Inspectors will often speak directly with employees to get a sense of the companyās safety culture. These conversations are typically private. It is important to remind employees they may be asked questions, and equally important for employers to avoid any form of retaliation.
Document request
Cal/OSHA will ask for written programs, training records and documentation of hazard correction. Having paperwork organized and easily accessible sends a strong signal that your operation is committed to safety and compliance.
Departure and next steps
Once the inspector leaves, gather your team for a debrief. Document everything that occurred, consult with legal counsel and prepare to respond promptly to any follow-up requests.
āBeing proactive about compliance can protect not only your bottom line but also the long-term sustainability of your operation.ā
Practical Steps for Growers
For many smaller farms, compliance may feel overwhelming. However, practical, consistent steps can make the process manageable:
ā¢ Review and update safety programs before each season begins.
ā¢ Keep signed training records on file along with training materials.
ā¢ Walk your worksites regularly, document hazards and fix them as soon as they are identified.
ā¢ Train supervisors and crew leaders on how to handle an inspectorās arrival and what to do.
ā¢ Stay ahead of new rules, particularly indoor heat illness and workplace violence prevention.
ā¢ Involve employees in identifying hazards and suggesting solutions. This builds trust and strengthens compliance.
By taking these steps, growers can turn compliance into a practical tool for protecting workers and strengthening their businesses. A written plan is only as strong as its implementation. Make sure your programs reflect the reality of your farm and equip your team to respond with confidence when Cal/OSHA comes calling.
If you need assistance developing your health and safety programs, have questions about plans or need guidance on safety or human resources issues, the AgSafe team is here to help. We also provide training tailored to your needs. Donāt hesitate to reach out. No question is too small. Contact us at 209-526-4400 or email us at safeinfo@agsafe.org.
