what to do when osha comes knocking
TRANSCRIPT
What to do to prepare for an OSHA Audit
Meet the Speaker
Rick Foote
OSHA Has Been Busy
• OSHA Conducted 92,000 inspections
• There were over 188,000 violations cited
• There was approximately $240 million in
penalties
Top 10 Violations
1. Fall Protection
2. Hazard Communication
3. Scaffolding
4. Respiratory Protection
5. Lockout/Tagout
Top 10 Violations6. Powered Industrial Trucks
7. Ladders
8. Electrical
9. Machine Guarding
10. Electrical, General
Requirements
Are you ready for OSHA to
knock at the door?
OSHA Inspections:Preparation is Key!
Form a Committee
• EH&S
• Facilities Dept.
• Maintenance
• Environmental Services
• Clinical Lab
• Researcher Admin.
• Radiology
• Pharmacy
• Plant Operators
Organize Internal Resources
• Preparedness Coordinating Committee
• Facility Program Managers/Experts
• Facility Inspector Escorts
• Logistics and Planning
• Roles & Responsibilities
• Communications
Inspection Preparedness
Coordinating Committee• Organizes and facilitates the Opening
Conference
• Works out schedule with the inspectors
• Coordinates inspections with department/program managers
• Conducts daily debriefings
• Organizes and facilitates the Closing Conference
Facility Inspector Escorts
• Introduces the inspector and convey seriousness of the interview.
• Intercedes when leading questions are asked during an interview
• Tactfully restates misunderstood questions to interviewee.
• Doesn’t allow unqualified people to respond to questions
OSHA Inspections - Tips• Be Prepared!
• Maintain up-to-date plans and records
• Know where documents are; be able to produce them in a timely manner
• Have a Preparedness Plan
• Records and Documentation Review• Assemble materials requested by OSHA
• Identify conference room (do not use offices) for records review
• Offer only requested documents for specific locations
• Make duplicate copies of records that they copy
The Inspection
Inspections: Logistics
and Planning• Internal Notification (“The
British are Coming”)
• Enacting the Preparedness Plan
• Opening Conference
• Coordinating a schedule with OSHA
• Debriefings with parties inspected
Opening Conference• State that the group has been assembled to help
facilitate the inspectors’ review & provide an open communication channel with key facility officials
• Outline positive working relationship with OSHA inspectors
• Discuss how important compliance is to your facility
• Who in upper management is involved and how often your department meets with them
• Obtain an understanding of inspection scope
Guidelines: Site Inspection
• Identify nature and scope of inspection
• Accompany each inspector at all times
• Cooperate, but do not offer information not requested
• Duplicate all records copied
• Take good notes, photographs, split samples
• Monitor employee interviews
• Conduct an exit interview for each area to get an idea of what they found
Facility Escort Guidelines
• Restate unclear answers from the interviewee to the OSHA inspector.
• Stay by the inspectors side
• Take notes
• During and shortly after the interview
• Of issues that the inspector notes during the inspection
• Of questions that could not be answered
Taking care of business
• Fixing Potential Violations
• As issues are found
• Prior to OSHA entry
• Before OSHA finishes for the day
• Behind the Scenes During the Inspection
• OSHA Location during the day
• Fielding questions
Closing Conference
• Consider having VP level
representative and
attorney present
• Present documentation of
correction actions taken
during the inspection
• Have answers to questions
that couldn’t be answered
in the field
More Guidelines
• Take notes
• Don’t attempt to deal with hypothetical situations
• “Fix” simple deficiencies along the way
• Make a copy of anything given to the inspectors
• Seek approval for all photos requested by the inspectors; take duplicate photos
• Likewise, take duplicate samples
Guidelines Continued…• Don’t offer an opinion or agree/disagree with
the inspectors
• Do talk about sports, music, general topics
• Don’t be their “buddy” or confidant
• Don’t sign anything
• Keep them from harm’s way (no confined
space entry or near high hazard areas)
Guidelines Continued…• Don’t offer information unless specifically asked
• Don’t argue with the inspectors
• Don’t complain about the regulations
• Don’t be pushed into giving an answer if you don’t know…say that you don’t know
• Don’t be evasive. Answer directly and succinctly
• Don’t lie to the inspectors or misrepresent what really happens in your area
• Don’t engage in speculation
Training Requirements
OSHA Regulations Requiring Training
• 1910.38 - Emergency Action
Plans
• 1910.39 - Fire Prevention
Plans
• 1910.66 - Powered Platforms
for Building Maintenance
• 1910.95 – Occupational
Noise Exposure
• 1910.106 – Flammable and
Combustible Liquids
• 1910.109 - Explosive and
Blasting Agents
• 1910.110 - Storage and
Handling of Liquefied
Petroleum Gases
• 1910.111 - Storage and
Handling of Anhydrous
Ammonia
• 1910.119 - Process Safety
Management of Highly
Hazardous Chemicals
• 1910.120 - Hazardous Waste
Operations and Emergency
Response
OSHA Regulations Requiring Training
• 1910.124 - General
Requirements for Dipping
and Coating Operations
• 1910.132 – Personal
Protective Equipment
• 1910.134 – Respiratory
Protection
• 1910.142 - Temporary Labor
Camps
• 1910.145 - Specifications for
Accident Prevention Signs
and Tags
• 1910.146 – Permit Required
Confined Spaces
• 1910.147 – The Control of
Hazardous Energy (lockout-
tagout)
• 1910.151 - Medical Services
and First-Aid
• 1910.155 – 1910.165 – Fire
Protection (includes portable
fire extinguishers)
OSHA Regulations Requiring Training
• 1910.177 - Servicing of Multi-
Piece and Single-Piece Rim
Wheels
• 1910.178 – Powered
Industrial Trucks (forklift
operator training)
• 1910.179 – Overhead and
Gantry Cranes
• 1910.180 – Crawler,
Locomotives and Truck
Cranes
• 1910.181 – Derricks (material
handling)
• 1910.183 – Helicopters (for
material handling)
• 1910.184 – Slings (material
handling)
• 1910.217 – Mechanical
Power Presses
• 1910.218 – Forging
Machines
• 1910.252 – 1910.255 –
Welding, Cutting and Brazing
OSHA Regulations Requiring Training
• 1910.261 - Pulp, Paper, and
Paperboard Mills
• 1910.262 – Textiles
• 1910.264 - Laundry
Machinery and Operations
• 1910.265 – Sawmills
• 1910.266 – Logging
Operations
• 1910.268 –
Telecommunications
• 1910.269 - Electric Power
Generation, Transmission,
and Distribution
• 1910.272 – Grain Handling
Facilities
• 1910.332 – 1910.333 –
Electrical Safety Related
Work Practices
• 1910.410 – 1910.440 -
Commercial Diving
Operations
OSHA Regulations Requiring Training
• 1910.1000 – Toxic and
Hazardous Substances
• 1910.1001 – Asbestos
• 1910.1003 – 1910.1016 –
Thirteen Carcinogens
• 1910.1017 – Vinyl Chloride
• 1910.1018 – Inorganic
Arsenic
• 1910.1020 - Access to
Employee Exposure and
Medical Records
• 1910.1025 – Lead
• 1910.1026 - Chromium (VI)
• 1910.1027 – Cadmium
• 1910.1028 – Benzene
• 1910.1029 - Coke Oven
Emissions
• 1910.1030 – Bloodborne
Pathogens
• 1910.1043 – Cotton Dust
OSHA Regulations Requiring Training
• 1910.1044 - 1,2-Dibromo-3-
Chloropropane
• 1910.1045 - Acrylonitrile
(Vinyl Cyanide)
• 1910.1047 - Ethylene Oxide
• 1910.1048 – Formaldehyde
• 1910.1050 –
Methylenedianiline
• 1910.1051 - 1,3-Butadiene
• 1910.1052 - Methylene
Chloride
• 1910.1096 – Ionizing
Radiation
• 1910.1200 – Hazard
Communication
• 1910.1450 - Occupational
Exposure to Hazardous
Chemicals in Laboratories
Preparedness
• Develop an OSHA compliance calendar
• Ensure all of the required written plans are up to date
• Develop a training matrix
• Keep records organized and ready for inspection
Be Ready!
Be Ready!
• Review the OSHA 300 Log
• Conduct internal inspections
• Involve employees to get their buy-in
• Enforce programs such as personal protective equipment, safety devices, etc..
Industrial Client• We did a survey to help identify potential
OSHA compliance issues and to train
employees on what to do when they arrive
• We identified numerous issues that needed
to addressed by client
• OSHA did a site visit several months later
and the facility was found to have no
violations in there program
Higher Education Client• The client was visited by OSHA regarding an
employee compliant
• We assisted the client with responding to the
complaint and then correcting the issue
• We also trained the staff on what to do when
OSHA comes back onsite
• OSHA did a follow up inspection and
commended them for the thoroughness of
the response
Thank You!
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