an overview of osha regulations and safety program audits at browz

SAFETY AUDITING & OSHA REGULATIONS

Contractor Prequalification & Management | www.browz.com

Presenters

Matt HeapSafety Manager

Allison GarzaOperations Director, BROWZ

Pat CunninghamDirector, Safety & Auditing Services


What we ‘ll cover:• Purpose of the presentation

• About BROWZ auditing & Supply Chain qualification

• Uploading written safety programs

• Regulatory overview

• How to read an OSHA standard

• BROWZ audit results

• Resources for written safety programs

• Q&A

Agenda


Purpose of the Presentation

Prepare BROWZ suppliers for upcoming Safety Program Auditing, OSHA regulations & insight for writing company safety programs


• Supply chain assessment & compliance

• Patented, configurable technology

• Supply Chain Specialist -single point of contact for contractors (suppliers)

• Providing assurance of a safer work environment

Who is BROWZ?


Good News: More reliance on contractors

Key drivers & increased use of contractors… • Lean-hiring practices, access to expertise that’s not available in-house &

flexible employment/staffing models

• Recent Campbell Institute symposium: contractors represent ~ 30% of the workforce

• Regulatory obligation to evaluate contractors prior to hire

• Qualification process (BROWZ supplier data-base out performed the BLS national average):

TRR = 57%, DART = 52%, LWD = 60%


First level: Desk top , Client specific, supplier self-disclosure : • Identified the potential hazard for each steps/task specific to the job

Second level: Safety Program Audit - typically using the BROWZ Standard “Big 6” (Fall Protection, PPE, Haz Com, EAP, CSE, LOTO)

• Client agreement, on programs to be audited, comparative standard, and element questions

• Some clients may have their own best practice checklists

• Objective: looking for program and element level evidence within a supplier’s written program

Third level: Specialty Audits - Client requested• These can actually be best practice assessments, or targeted compliance audits that can be

refined down to Consensus standards

• Objective: looking for program and element level evidence within a supplier’s written program

Levels of BROWZ Auditing


• Click , My Account from upper menu

• Click , Environmental – Health – Safety section in left side menu

• Answer three safety admin. questions

• Click, Document icon below question

• Click , ‘Add’ [Note: 10 MB limit]

• Select file and click ‘Save & Continue’

• Click, ‘Return to Previous Page’ to return to section

• Click ,‘Save & Continue , or ‘Save Current Page’ to save answers to questions

Uploading Safety Programs


Regulatory Overview

BROWZ Safety Manual Audits Written at the Federal Level• State Plan requirements left at the site level (22 State or Territory plans)

• General Industry (1910)

- OSHA uses the term "general industry" to refer to all industries not included in agriculture, construction or maritime

• Construction (1926)

- Comprises a wide range of activities involving construction, alteration, and/or repair

• Which regulation applies depends on the work, not the employer type


Regulatory Overview

Other Applicable OSHA Information

• General Duty Clause (OSHA Act of 1970, Section 5, “Duties”)

(a) Each employer: (1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees; (2) shall comply with occupational safety and health standards promulgated under this Act.

(b) Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.

• OSHA’s catch-all for citations (after-the-fact, no specific regulation)


Multi-Employer Citation PolicyCPL 2-0.124, published 12/99:

• On multi-employer worksites (all industry sectors), more than one employer may be citable for a hazardous condition that violates an OSHA standard (types of employers):- Creating – created the unsafe condition

- Exposing – their employee’s were exposed

- Correcting – responsible for installation/maintenance

- Controlling – worksite supervisory authority

Regulatory Overview


OSHA Web Page: www.osha.govDefinitions: "Shall" = mandatory "Should" = recommendedStandard Interpretation: Preambles, Letters of Interpretation, DirectivesIndustry catch-phrase about OSHA: “If it didn’t get documented, it didn’t get done”

Notable OSHA Information


Breaking Down the Number: 29 CFR 1910.66(e)(2)(iii)(A)(4)Subpart: F, Subpart Title: Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms , Title: Powered Platforms for Building Maintenance

“Building anchors which extend beyond the face of the building shall be free of sharp edges or points. Where cables, suspension wire ropes and lifelines may be in contact with the building face, external building anchors shall not interfere with their handling or operation.”

How to Read an OSHA Standard

Title Code Part Section Lower Case

Arabic #

Lower Case Roman

Capital Upper Case

Arabic #

29 CFR 1910 .66 e 2 iii A 4


A = General

B = Std. Adoption

C = [reserved]

D = Surfaces

E = Exits

F = Manlifts

G = Health & Enviro.

H = Haz. Materials

I = PPE

J = Enviro. Controls

K = First-Aid

L = Fire Prot.

M = Comp. Gas

N = Hand. Materials

O= Mach. Guarding

P = Port. Tools

Q = Weld. Cutting

R = Spec. Ind.

S = Elect.

T = Diving

U – Y = [reserved]

Z = Toxic Sub.

OSHA Subparts – General Industry (1910)


A = General

B = Interp.

C = S& H

D = Enviro. Controls

E = PPE

F = Fire Prot.

G = Signs, Signals

H = Hand. Materials

I = Tools, Hand/Pow.

J = Weld. Cutting

K = Elect.

L = Scaffolds

M = Fall Prot.

N = Cranes, Hoists

O= Motor Vehicle

P = ExcavationsQ = Concrete, Mason.

R = Steel Erection

S = Tunnels, Shafts

T = Demo.

U = Explosives

V = Power Trans.

W = Rollover Prot.

X = Stairways, Ladd.

Y = Diving

Z = Toxic Sub.

OSHA Subparts – Construction (1926)


BROWZ Audit Results – Overview


BROWZ Audit Results – Element Detail


Free Resources:- OSHA web site, “Small Business”

- Sample programs

- OSHA eTools

- OSHA's On-site Consultation Program

- Journey to Safety Excellence (National Safety Council: free assessment tools & resources)

- Your insurance provider

Resources for a Fee:- Local Chapters of the National Safety Council (Non-Profit, not in each state)

- National Safety Council (Non-Profit, available nationally)

- Outside vendors – program templates (For Profit, caution: program without thought-investment = “moving a problem down the line”)

Resources for Written Safety Programs


• Why doesn’t BROWZ provide written templates? independent 3rd party auditor; belief that each company must engage themselves – assessment, training, purchasing, maintenance

• Q: Which Standard Applies? (A: 1926 applies for construction operations; 1910 applies for most other operations.) “When in doubt, apply the most stringent standard.”

• Why can’t we cut/paste OSHA regulations for our Safety Manuals? (OSHA = ‘what’, Company = ‘how’)

Common Supplier Questions


Questions & Contact Info

Matt HeapSafety [email protected]

Allison GarzaOperations Director, [email protected]

Pat CunninghamDirector, Safety & Auditing [email protected]

an overview of osha regulations and safety program audits at browz

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