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Risk and Safety Audits Staying ahead of OSHA
Presented by
Mark J. Barros Brian A. Oatman
May 05, 2015
ANR Risk and Safety Services
About UC ANR
ANR is a UC system wide division throughout California. 75 locations: • Cooperative Extension • Research and Extension Centers • Statewide programs
Why Conduct a Safety Audit?
Required by OSHA • Cal-OSHA 8-3203 requires scheduled periodic inspections to
identify unsafe conditions and work practices.
Reduce accidents, injuries and deaths Reduce agency violations and fines Identify unsafe trends Develop safety awareness Provide a safe and healthy work environment
Top 10 Fed OSHA Violations 2014
Violations Number of Violations 1. Fall Protection 6,143 2. Hazard Communication 5,161 3. Scaffolding 4,029 4. Respiratory Protection 3,223 5. Lockout/Tagout 2,704 6. Forklifts 2,662 7. Electrical Wiring Methods 2,490 8. Ladders 2,448 9. Machine Guarding 2,200 10. Electrical - General 2,056
Costs of Violations (Cal-OSHA)
Type of Violation Penalty
No Heat Illness Plan $350 to $1,000
No Injury Illness Prevention Program $350 to $1,000
Not reporting a recordable injury $5,000
Missing PTO guard on a tractor $3,000 to $5,000
Field restroom inspection failure $750
No seatbelts on tractors or damaged $3,000 to $5,000
Chemicals misused, unlabeled $5,000
Damaged electrical extension cords $750
Failure to maintain training records $500 to $7,000
History of ANR Safety Audits
The Unfriendly Safety Audit
• By the Administration Office to punish a facility or person(s) • Enforce “unwritten” policies and procedures not based on regulations • A method to bully or embarrass • The Safety Audit became personal.
The Friendly Safety Audit
• The Safety Audit became a consultation service • Violations were based only on regulations and written policies • Became non-personal • To eliminate potential agency violations and fines
ANR Safety Audit Procedures
Two types of Safety Audits Annual Scheduled Safety Audits • A formal safety audit of the overall safety program of the facility. • Intent is to determine the status of the facilities safety program and assist
with any non-compliance issues and concerns.
Unannounced Safety Audits • To simulate a surprised inspection from a regulatory agency (Cal-OSHA) • The unannounced audit is to provide guidance on how to “survive” an
agency inspection. • Generally up to three subjects are picked for the unannounced audit.
Safety Audit Procedures
Prior to starting a Safety Audit
Pre-Safety Audit Meeting • Explain to the responsible facility staff, the purpose and procedures of the
Safety Audit. Answer any pre-audit questions and concerns of the process.
• Request a facility representative to escort the Safety Auditor through the facility during the audit and take notes of observations made by the Safety Auditor.
Safety Audit Checklist
PERIODIC WORKSITE INSPECTION CHECKLIST
Top Ten ANR Audit Violations
1. Fire Extinguishers • No identification sign posted • Missing or out of date service tag • Access blocked • Monthly inspections not conducted • Fire extinguisher not mounted
Top Ten ANR Audit Violations
2. Hazard Communication • Chemical containers without labels • Missing Safety Data Sheets
Top Ten ANR Audit Violations
3. Housekeeping • Unsafe storage of materials • Spilled waste oil on bin and ground • Leaking oil
Top Ten ANR Audit Violations
4. Aisle & Walkways • Inadequate clearance • Slip, trip and fall hazards • Obstructed exits
Top Ten ANR Audit Violations
5. Live Loads • Materials stored over 6’ in height without a retainer • Materials stored improperly
Top Ten ANR Audit Violations
6. Emergency Action Plan • No Action Plan available • The plan is incomplete and does not comply with code • Emergency Action Plan is not up to date
Top Ten ANR Audit Violations
7. Hazardous Waste Management • Storage of waste beyond regulatory time limits • Hazardous waste in damaged containers • Waste containers left open
Top Ten ANR Audit Violations
8. Electrical Equipment • Exposed wiring or shielding • “Daisy chained” power strips • Access to electrical control panels blocked • Control panels and switches on breaker boxes not identified • Extension cords being used as permanent wiring • GFI protection not provided at water sources
Top Ten ANR Audit Violations
9. Labeling of Hazardous Waste • No labeling of hazardous waste • Improper labeling of hazardous waste • Missing information on the label
Top Ten ANR Audit Violations
10. Machine Guarding • Guards missing • Guards damaged • Guards do not fully protect employees
Safety Audit Report
Definitions of Hazard Evaluations
MINOR • Will not cause physical injury and may not result in an agency
violation or a non-fine violation. MODERATE • Hazard may cause mild injury or some damage to equipment.
Operations or machinery might not be stopped. SERIOUS • Hazard may cause serious injury anytime. Hazard may be
corrected immediately or before task or equipment is used. Equipment may be “Red-Tagged” and taken out of service.
IMMINENT • Hazard likely to cause immediate serious injury or death. Task
must be stopped and hazard corrected immediately before continuing. Found during an operation or task.
Corrective Actions Status
Facilities will submit a status report (response) of the corrective actions taken. • Serious violations are to be corrected within 30 days.
• Moderate and Minor violations are to be corrected within 60 days.
If a violation is a time consuming and or costly issue, then it can become a project. Corrective actions should be noted in the Safety Audit report and returned to the Safety Auditor.
Results
Results of safety reviews • 10% findings “minor” • 60% of findings “moderate” • 30% of findings “serious” • < 1 % of findings “imminent” Improved compliance (Downward trend of total findings per year)
50
70
90
110
130
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190
1998 2000 2002 2004 2006 2008 2010
Ite
ms
Fou
nd
Ten Year Trend of Audit Findings
Items Found
Trendline
Results
Compliance Record From Regulatory Inspections • 134 inspections since 1995 • 90 inspections – No violations • 30 inspections – minor findings or corrective
actions • 6 fines = $29,100
Risk Audit
• Meet with County or Center Director, Office Manager, Program staff
• Review of policies and procedures for: • Facility Use Agreements • Certificates Of Insurance • Criminal Records Checks • Incident Reporting • Insurance Claims • Travel Insurance • Whistleblower poster • General Risk Assessment
Risk Audit
• Broad-based Risk Assessment • Open dialogue with key personnel • What are conditions or events that could prevent
ANR from achieving objectives? • What are concerns that keep you up at night? • Include results in reports to senior leaders, and risk
assessment reporting to UC Office of the President
Safety Note #111 provides tips for surviving a regulatory inspection. http://safety.ucanr.edu/files/1355.pdf
Surviving a Regulatory Inspection
Before the inspection: • Have records well organized and accessible. When the inspector arrives: • Verify the inspector’s credentials. • Request an opening conference. • Ask the inspector what prompted the inspection (such as complaint,
accident, etc.) - they may not answer, but it could help you understand what they want to see.
• Ask what areas they want to visit and what records they want to see. • In some cases you may need to notify labor unions, if the inspection
involves represented staff members.
Surviving a Regulatory Inspection
During the inspection: Answer questions honestly and succinctly:
Do not volunteer extra information. Do not speculate or share gossip. Be responsive to requests for information - if you can't find something, promise to follow-up, and then follow-through. Ask questions if you do not understand what the inspector wants. Don't point out perceived problems; let the inspector tell you. Correct non-compliant items immediately (during the inspection) if possible. Bring along a camera and take photographs of any conditions that the inspector photographs.
Subjects an inspector may look for: • Records (of training, self-inspections, monitoring, waste manifests, etc.). • Internal operating procedures or safety practices. • Knowledge of regulations/standards/permit conditions. • Follow-through on responding to issues (i.e.: accident investigations,
reports to agencies for permits, etc.).
Surviving a Regulatory Inspection
Request a closing conference: • Ask about findings. • Ask about severity of any violations that the inspector reports. • Ask when you can expect a report - note: some local agencies will give you
a report at the conclusion of the inspection. Some state or federal agencies may take months to issue a report.
After the inspection: • Contact your EH&S or Compliance office and provide a summary of the
inspection. They may be able to help you with corrective actions or interpretations of the regulations.
• Follow-up on any items agreed to during the inspection. • Adhere to any corrective action or submittal deadlines. • Retain a copy of the inspection report and provide to EH&S Office and/or
University Counsel
Surviving a Regulatory Inspection
Do’s • Be honest • Understand the purpose of the inspection and review relevant records
prior to on-site inspection • Listen carefully and understand each question before answering. Be sure
responses are complete and accurate. • Respond only to the question asked; keep answers simple and direct. • Weigh answers carefully, being certain you have the facts to back them up. • Limit comments to areas where you have “first hand” knowledge. Don’ts • Do not speculate or answer hypothetical questions. • Do not agree or disagree with opinions. • Do not “ramble” or provide irrelevant information. • Do not get offended by “why?” questions. • Do not sign any admission or settlement of a violation on behalf of your
institution, unless you are authorized.
Surviving a Regulatory Inspection
University of California Agriculture and Natural Resources
Risk & Safety Services
http://ucanr.edu/safety http://ucanr.edu/risk
For More Information
Brian Oatman Director, Risk & Safety Services [email protected] 530-750-1264
Mark Barros EH&S Supervisor [email protected] 530-750-1262
