Mold Release, Cleaner & Rust Preventive White Papers
By Dave Malter, President, Malter Associates, Inc.
OSHA compliance is something that is expected from everyone every day. Will you and your workplace be ready when the inspector comes to your door?
Let’s explore three key issues of OSHA inspections:
1) Why?
Reasons why an OSHA inspection could occur at your facility.
2) What?
Programs and documents OSHA inspectors will ask to examine when they arrive at your workplace.
3) How?
Things that you can do to effectively manage the inspection process.
OSHA Inspections will occur as the result of:
1. Imminent Danger
2. Employee fatality
3. Employee multiple inpatient hospitalization
4. Employee complaint
5. Agency referral (e.g., fire department)
6. Targeted Inspections (due to elevated DART and DAFWII Rates), or
7. National Emphasis Program (e.g., explosive dusts)
An Imminent Danger is a workplace hazard that puts you at immediate risk of death or serious physical harm
An employee or referral complaint is often the cause of an OSHA inspection. At least one of the following eight criteria must be met for OSHA to conduct an on-site inspection based on an employee or referral complaint:
Sometimes OSHA sends a letter to you instead of conducting an on-site inspection. If that happens, you will receive a letter from OSHA identifying allegations of violations of one or more OSHA regulations. Generally, OSHA is requesting that the location manager respond to the facts surrounding these allegations within fifteen working days. Failure to do so may result in an inspection of the facility.
What?
When OSHA arrives at your door, after they present their identification to you they will conduct an opening conference. After the Opening Conference, OSHA Inspectors will generally:
Key inspection areas often include:
Topic |
Documents |
• Work Related Injuries and Illnesses |
• OSHA 275, 275A, 301 • Current, plus past 5 YR • Training |
• Emergency Management |
• Evacuation Plans • Response Plans • Emergency Drills • Training |
• Hazard Communication |
• Written Program • MSDS/SDS • Contractors • Training |
• Personal Protective Equipment |
• Hazard Assessments • Selection • Training |
• Lockout and Tagout |
• Machine Specific Lockout Procedures • Periodic Inspections • Contractors • Training |
• Electrical Safety |
• Electrical Safe Work Practices (plus 70E) • Training |
• Powered Industrial Trucks |
• Classroom Training • Driver’s Evaluations • Post-Accident/Near Miss/Observation • Modification/Rerating Certifications • Vehicle Inspection Records |
• Respiratory Protection |
• Air Sampling Results • Appendix D • Medical Evaluations • Respirator Selection • Fit Tests • Periodic Observations/ Inspections • Training |
• Noise and Hearing Conservation |
• Noise Sampling Results • Engineering/Administrative Controls • Audiometric Testing • Hearing Protector Selection • STS Management • Training |
• Machine Guarding and Power Press Safety |
• Operator, Maintenance, and • Lockout Procedures • Lockout By-Pass Procedures • Set-up (e.g., Die Setting) Procedures • Machine Safeguard Inspections |
• Cranes and Slings |
• Frequent Crane Inspections • Periodic Crane Inspections • Periodic Sling Inspections • Modification/Rerating Certifications • Training |
How?
You must be proactive to minimize the potential impacts of an OSHA inspection. Ask yourself a few simple questions:
When you receive an inspection, Rule #1 is cooperation. It is a good policy to cooperate fully with federal and state OSHA personnel and to permit them to conduct proper investigations within the scope of their authority. They are usually there for a legal purpose and your cooperation will generally make the process easier for both parties. But, this is your facility and there is a lot that you can influence during the process.
Do’s and Don’ts
Preparation is the key to reducing the impacts of any inspection. You can minimize work related injuries and illnesses and be prepared for any inspection at your facility if you develop and implement good programs and procedures for accident prevention and compliance. Once you do, be sure to implement your own quality control of the process. Check your workplace and the work that is done by your employees and contractors. Make corrections where needed. If an inspection occurs, you will be ready.
Dave Malter is President of Malter Associates, Inc. He has been a health and safety professional for more than 35 years. He has served as a Compliance Officer for the Occupational Safety and Health Administration (OSHA), as an Industrial Hygienist for the US Department of Energy, as the Industrial Hygiene Manager for the Santa Fe Railway Company and as the Director, Health, Safety and Transportation for Waste Management, Inc. He is a Certified Industrial Hygienist, Certified Safety Professional, Licensed Industrial Hygienist, Registered Occupational Hygienist and a Certified Professional Environmental (Health and Safety) Auditor in Health and Safety. Mr. Malter performs mock-OSHA inspections to prepare clients for OSHA inspections, provides assistance when inspections occur and helps clients develop the processes to enhance the processes for accident prevention and compliance. He can be reached at (214) 973-5500 or at dmalter@malterassociates.com.
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