The Association of Equipment Manufacturers (AEM), an industry group representing 1,000+ manufacturers, has petitioned Cal/OSHA about making changes to a rule governing the use of highly automated agricultural equipment.

California Code of Regulations, Title 8, Section 3441(b), directed toward all “self-propelled equipment,” mandates that an operator remains at an operator station when the equipment is in motion. (The operator station can be located outside of the normal operator station.) 

The AEM says the regulation, as drafted, would negate many of the benefits of highly automated agricultural equipment and autonomous agricultural equipment.

According to Cal/OSHA, the regulation only applies when there are workers in the field along with the autonomous equipment, which is the case with many agricultural tasks.

The organization is proposing two two avenues that can be pursued to allow this equipment to be used as intended:

Each farm wanting to use highly automated agricultural equipment and autonomous agricultural equipment can request a variance, which would be applicable for all of the locations of the farm granted the variance. In other words, only one variance would apply to all of the requesters’ locations. While individual variances may be the quickest way to gain approval to use highly automated or autonomous self-propelled equipment, each farmer would need to request such a variance.

Request that the regulation be changed. This will take longer, but is the more inclusive and permanent means to allow full use of highly automated agricultural equipment or autonomous self-propelled agricultural equipment, and will set the stage for their continued market access in the future.

AEM says its staff has worked with the AEM Agricultural Product Safety and Compliance Council to draft a simple proposal to add a paragraph allowing the use of highly automated agricultural equipment or autonomous self-propelled agricultural equipment in California, even in the presence of workers. This petition was sent to the Occupational Safety and Health Standards Board in Sacramento, California. AEM now awaits the board’s consideration and ruling on its request.