Walk through your business and check all chemical container labels, fuse boxes, fire extinguishers, noise levels, air quality levels and obstructed views. Make sure that desk chairs and computer work stations are ergonomically compliant. Tornado, fire, flood and earthquake procedures and evacuation routes or shelters must be clearly posted.
Asking yourself 'what if' questions is an effective way to assess workplace potential for chemical, physical, ergonomic and biological hazards. Make a check list of hazard violations and the date each was corrected.
Regularly review rules with your employees to determine if they are not only understandable but absolutely necessary. Too many safety rules can cause employees to ignore them.
New employees should complete training upon being hired, and all employees should participate in annual safety training.
With a few exceptions for specific industries, most companies with 11 or more employees must keep injury and illness records.
Tips & Tactics
• Helpful advice for making the most of this Guide
• Purchase a copy of national OSHA guidelines and those for your state.
• Read up and know what OSHA requires.
• Inspect and correct all recognizable health and accident hazards.
• Review workplace regulations for clarity and necessity and thoroughly train all current employees and new hires.
• Prominently post safety regulations and emergency procedures.
• Keep an accurate accounting of work related incidents for each employee.
How to prepare for an OSHA inspection
Feb 5, 2009 at 9:00 AM
by Ellen R. Wright and Gregory S. Narsh, Esq.
An unexpected visit from a government regulator such as the Occupational Safety and Health Administration (OSHA) is often unwelcome—and unsettling, too. If you have taken the time to prepare for an OSHA inspection, however, it need not be traumatic.
Advance planning and preparation not only make the inspection proceed without difficulty, but allow you to be in control. Plus, being prepared may make a good impression on the inspector, which could lead to being cited for fewer violations.
OSHA inspectors typically want to review several documents that you may be required to keep at your facility:
Your company's Injury and Illness Prevention Plan and all supporting documentation
• OSHA Log 300
• Lockout/tagout procedures
• Emergency and fire plans
• Respiratory protection plan
• Hearing conservation program
• Hazard communication program
• Material Safety Data Sheets
Not all are required at every workplace—you'll have to determine which apply to your organization.
What triggers an inspection?
Many inspections result directly from employee complaints or in response to reported accidents.
Before 1996, your workplace would likely be the target of an inspection based solely upon the nature of your business (e.g., steel manufacturing). Since 1996, OSHA has been using different criteria to determine which workplaces will be inspected.
That's when OSHA established the Data Collection Initiative (DCI) to gather data from more than 80,000 employers in select industry classifications. OSHA requested injury and illness information from such employers, which it then used as justification to target industries with higher than usual numbers of employee injuries and illnesses.
As a result, OSHA developed two categories of inspections: programmed and nonprogrammed. If your inspection is deemed a programmed inspection, it probably means that OSHA is inspecting your work site on the basis of your (or your industry's) answers to the DCI survey. If an inspection is nonprogrammed, you may have experienced a serious event (such as a fire or explosion) or a workplace fatality. OSHA may have received complaints or referrals regarding your work site.
Passing inspection
Follow these steps to increase the odds of a successful inspection:
Designate one person who is fully trained on your safety and health procedures to talk with the inspector and escort him or her around the facility. Make it company policy that only the designated person may conduct such a tour.
Gather the required OSHA documents in an area isolated from proprietary or confidential information. Present them in a form that is convenient for the inspector.
Anticipate safety and health issues if possible, and have a response prepared.
Control the route the inspector takes through the facility, and how information is communicated to the inspector.
Be proactive. Inquire about the inspector's concerns during the inspection. If possible, correct deficiencies immediately. When appropriate, explain why an apparent deficiency does not deserve a formal citation. The inspector will typically hold a closing conference with you before leaving. This is an opportunity to discuss potential citations and try to resolve them then and there.
Don't be pressured. If the inspector asks a question or requests a document that you are unsure of or uncomfortable about, stop and take the time to consult a superior—or an attorney. Don't feel you have to always provide an instant response. You don't.
Don't volunteer or admit noncompliance. You should, however, cooperate with the inspector.
The inspection process
OSHA inspectors have the right to inspect any part of the facility and request copies of any OSHA-required documents. They have the authority to interview employees without any member of management present.
It is wise to:
• Choose a route that exposes the least amount possible to inspection (if the inspector is there to see a specific area)
• Know which documents are required of your facility and keep them separate from other documents
• Establish and maintain the best possible working relationship with OSHA representatives
An employer has the right to refuse access to the facility and demand an administrative search warrant, but this is rarely recommended. In deference to the agency and in the interest of worker (and public) safety, such a warrant will not be difficult to obtain. It is generally best to cooperate with OSHA while remembering that you do have rights and you can refuse certain requests.
National Hearing Conservation Association Petitions OSHA to Lower Permissible Exposure Limits for Noise
WESTMINSTER, Colo., Nov. 2 /PRNewswire/ -- Citing the fact that nearly 22 million American workers are exposed to hazardous noise on a daily basis and that occupational hearing loss continues to plague industry, the National Hearing Conservation Association (NHCA) has made a request to the Occupational Safety and Health Administration (OSHA) to reduce the permissible exposure limit (PEL) for noise exposures.
"Noise-induced hearing loss is an insidious, permanent, and irreversible disease which has a tremendous negative impact on people's lives. The good news is that this disease is 100% preventable," said Rick Neitzel, PhD, CIH, NHCA President. "The bad news is that OSHA's 30-year-old noise exposure regulation is not consistent with current scientific knowledge, is not uniformly applied across all industries, and has not proven effective in preventing noise-induced hearing loss (NIHL)."
NHCA has requested that OSHA lower the PEL in the Occupation Noise Standard 29 CFR 1910.95 from 90 dBA to 85 dBA, and the Action Level from 85 to 80 dBA. Citing recent research by NIOSH and other organizations, American workers face a considerable risk of NIHL associated with long-term work at the current PEL of 90 dBA and a 5 dB time/intensity exchange rate. NHCA has also requested that the time/intensity exchange rate be reduced from 5 to 3 dB.
In the letter, NHCA also requests that OSHA extend the PEL to other industries, such as construction, agriculture, oil and gas drilling and servicing, and shipbuilding, that are not covered by the existing regulation. NHCA also asks OSHA to rescind a policy (OSHA Field Operations Manual, 3/2009) which permits exposures up to 100 dBA without requiring implementation of noise controls.
Fall protection is still high on OSHA's lists of violations
Daily Journal of Commerce (Portland, OR),Nov 6, 2009 by Justin Carinci
Recently released federal and state safety data show that fall protection remains a top concern. According to preliminary federal Occupational Safety and Health Administration data for the 12 months ending Sept. 30, fall protection had the second-highest number of violations.
The previous year, fall protection ranked third, behind hazard communication; scaffolding problems resulted in the most violations both years.
Fall-protection violations topped Oregon OSHA's most recent list, posted Thursday, for the 2008 calendar year. That marks the fourth straight year at No. 1.
Despite that distinction, the total number of violations cited by Oregon OSHA actually fell to their lowest level since 2004. Fall- protection violations peaked at 510 for 2007 and dropped to 402 for 2008.
Of those 402 violations, 386 came from construction sites. That's down more than 100, from 497 the previous year.
Melanie Mesaros, Oregon OSHA spokeswoman, said efforts to reduce falls at construction sites have paid off, although it's hard to pinpoint the effectiveness of any single prevention campaign. "We definitely have been focused on fall protection as an issue and have been reaching out to that community to get these numbers down," Mesaros said.
The recession also might be helping construction-site safety, said Eliot Lapidus, safety and loss control manager for the Associated General Contractors Oregon-Columbia chapter. Because contractors aren't as pressed for labor, they can increase safety prequalification requirements in contracts.
"Given the economy and the slowdown in activity, you tend to see more prequalifications," Lapidus said. "You can be more selective, and contractors naturally want to have as safe a workplace as possible."
Even with work sites getting safer, falls remain a problem on multistory commercial projects, Lapidus said. "If somebody falls, it's a concern," he said. "People tend to be not only injured, but injured seriously."
Falls have haunted the residential construction industry for years, said Jim Fisher, former owner of a roofing company and current safety consultant. Roofing and home building associations have worked to change that.
"They have come miles in the last 15 years," Fisher said. "People weren't using any safety (measures) at all.
"Now, they get out of the truck, drop the harness on the ground and put it on."
Whereas the recession might have a positive effect on commercial jobsite safety, it has the opposite effect on the residential side, Fisher said. Homeowners choosing between a bid that includes safety precautions and one that doesn't, often pick the latter because of the lower price.
"On a $10,000 roof, it could be $800 to $1,200 higher," Fisher said. "So they say, 'I'm going to use Mike's roofing,'" a hypothetical company. "And Mike has no clue about safety."
Interest in safety has spiked in the last few years, said Fisher, who holds safety workshops with Oregon OSHA. Two years ago, he expected 25 roofers to attend a workshop, and 75 showed up. Six months later, the same workshop again attracted a standing-room- only crowd.
That bodes well for the future, Fisher said.
"The biggest thing (home builders) can do is realize there is a problem and then to diligently work to fix it," he said. "It's all about awareness and attitude."
Copyright 2009 Dolan Media Newswires
Provided by ProQuest Information and Learning Company. All rights Reserved.
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OSHA Violation of the Week - What were they Thinking?
