LIVERMORE, Calif. – August 31, 2022 – On June 16, 2022, Cal/OSHA's 4-3 opinion to deny petition 596 was the decision heard around the agricultural world. Filed by Monarch Tractor on December 15 of the previous year, petition 596 sought to clarify the state of California’s agricultural equipment regulations as they relate to modern self-driving tractors.
Monarch Tractor—the innovative company behind the world’s first fully electric, driver optional tractor—argued that the current regulations, which were drafted in the 1970s, fail to account for many of the ways tractors and other farming equipment have advanced in the 21st century. Although the Occupational Safety and Health Standards Board staff agreed with Monarch Tractor that the language that appears in Title 8, section 3441(b) may be outdated, this opinion was not enough to convince Cal/OSHA to approve the petition.
Many industry experts lamented this decision as a step backward for California agriculture. Without a quicker way to introduce the latest technologies on the farm, they argued, the largest agricultural state in the U.S. would surely be left behind. Autonomous tractors and other ag robotics are, after all, a necessary part of feeding a growing population in the face of labor shortages, rising input costs, fewer resources and increasing environmental concerns.
While it's true that advancing technologies provide solutions to many of these problems, the decision to deny Monarch Tractor's petition does not extend the timeline for bringing new autonomous equipment into the field. Quite the opposite. When Monarch Tractor filed the petition, the company sought to speed things up. The Board’s opinion merely maintains the status quo.
“The decision does not change current regulations,” says Monarch Tractor’s CEO Praveen Penmetsa. “There are already autonomous technologies operating on farms across the country. Monarch Tractor’s petition aimed to make the adoption of autonomous technologies on the farm easier, faster, and with less paperwork for farmers.”
Although Monarch Tractor brought a strong case to the Board and hoped that its petition would be approved, this decision did not negatively impact the ways the company and Cal/OSHA are collaborating at present. This includes the temporary experimental variance that’s been in effect since the summer of 2021. Through this variance, Monarch Tractor works with Cal/OSHA and Wente and Crocker & Starr vineyards to gather data in support of the conclusion that autonomous tractors provide the same level of safety as tractors managed by human operators.
“Monarch Tractor is the only company operating under this type of variance in the ag sector, despite various companies rolling out autonomous agriculture equipment,” Penmetsa says. “Despite the ruling, Cal/OSHA and Monarch Tractor continue to work closely under the temporary experimental variance to clarify the regulations, as well as establish safety processes with key milestones for other tech providers to follow specifically in farm environments where autonomous equipment is expected to work in close proximity to farm workers.”
Safety has long been a priority for Monarch Tractor, as the company has sharing information and collaborating with Cal/OSHA for the last three years. At the time of the petition, Monarch Tractor revealed that its technology has “operated 760 hours with zero incidents of any kind.” This provides a stark contrast to the labor statistics Monarch Tractor included in the petition:
According to the Bureau of Labor Statistics, agriculture is the deadliest profession in the United States and in the State of California with roughly 40% more deaths per 100,000 workers than any other industry [Fatal Occupational Injuries in California 2013-2019 (CFOI) Report. Pg, 18]. Tractor accidents are a leading cause of serious injury, accounting for about one-third of farm fatalities annually. The majority of tractor fatalities are from side or rear rollovers that can occur due to a range of factors including improper weight distribution, user error, and bad terrain conditions. Rollovers can happen to any operator; roughly 80% of fatalities involve experienced operators [NASD Tractor Overturn Information].
Monarch Tractor continually seeks to improve worker safety by outfitting its equipment with the latest sensors and camera technologies. The company referenced these advances when comparing the outdated language in Title 8, section 3441 (b) to what autonomous tractors can do now. Monarch Tractor’s petition argued that the technology in self-propelled tractors available today functions as an operator, which means the vehicle perform safely without an operator inside the tractor. Instead, the operator would manage the autonomous tractor’s work from a distance.
“Monarch has incorporated several additional safety features with direct input from Cal/OSHA,” Penmetsa says. “Tractors are speed limited in autonomy mode to 3mph and feature digital safety guardrails that deploy whenever a human is within 10m (33ft) of the vehicle. Monarch Tractor also enables 360-degree cameras to help protect the driver, surrounding people, livestock, implements, and crops near the tractor from crashes. The tractor actively addresses power take-off (PTO)-related injuries on the farm by utilizing a camera above the hitch that will stop the tractor and cut off power to PTO if an object or person comes in close proximity to the tractor.”
With the temporary experimental variance in place until August 2026, Monarch Tractor, Cal/OSHA and Wente and Crocker & Starr vineyards will continue gathering data. When the variance ends, the data will be used to evaluate whether the current regulations should be changed or updated. Many hope that this information will help make the case for quicker, easier adoption of autonomous farm technologies without sacrificing worker, bystander or animal safety. Penmetsa is committed to continuing this important work.
“Monarch Tractor continues to partner with other agricultural groups and California agencies on clarification of the regulations applicable to autonomous operations in agriculture,” he says. “Monarch Tractor will also continue to work with Cal/OSHA under the current variance to provide the data requested for evaluation under the variance as the leader in global farm autonomy.”
