Preparing For An Osha Inspection

PREPARING FOR AN OSHA INSPECTION

by Bill Grieb

This issue is on inspections: What is the Occupational Safety and Health Administration (OSHA) looking for, how to prepare, and an inspection checklist.

If you will use this checklist to look for safety hazards in your workplace you might be able to prevent an accident.

It is important to document improvements and cost savings that your safety and inspection program provide.

While inspecting your site for safety hazards, don't forget to look at each operation and consider engineering changes that can improve workplace safety and reduce the risk of injury. Evaluate any use of hazardous materials for the possibility of substituting less hazardous materials.

Federal OSHA reports only 24,000 inspections in 1996. This is almost 20% less than in 1995 and over 40% less than in 1994.

Many union officials feel that this is a major threat to improved workplace safety and health. The Wall Street Journal quotes Peg Seminario, the AFL-CIO director of safety and health: 'The threat is quite troubling and problematic. Without more enforcement, OSHA is no longer a credible threat.'

OSHA claims that there are multiple reasons for this decline. They cite a hiring freeze and the government shutdown. They claim that a great deal of the decline is due to 'reinventing OSHA.' They cite the agency's move to cooperate with business rather than penalize them.

My opinion is that irrespective of the level of surveillance by OSHA, accidents cost big money, and an effective Workplace Safety and Hazard Communication Program is the best insurance you can have. It will also reduce your insurance costs, which are based on your previous safety claims.

In 1994, more than 15,000 businesses were fined a total of $2,400,000.00 for HazCom violations. These fines were levied in both general industries and construction firms. The most frequent citations were:

• No written HazCom plan
• Missing MSDS (Material Safety Data Sheets)
• Lack of proper employee training
• Labeling errors or not labeling containers

One of the best ways to prevent workplace injuries and illnesses is a comprehensive inspection program.

Regular inspections should be an integral part of your Workplace Safety and Hazard Communication Program.

After a discussion on how OSHA goes about an inspection, there is an extensive checklist that you can use to inspect your workplace.

This list cannot be complete since each worksite is unique.

Additional pages of miscellaneous items should be prepared with items added as needed to adapt this inspection program to your workplace.

A common characteristic of effective safety programs is participation by both management and workers.

Management must participate by providing safety resources, pledging a strong commitment to safety, and setting an example through following and enforcing safety rules.

All workers need to participate in the safety program by maintaining awareness and focus on safety and making suggestions to improve workplace safety.

Safety improvement suggestions should be solicited, acted upon, and rewarded.

Remove dangers when noted prevents injuries.

What do those folks from OSHA look for in inspections? Well, we've X-rayed their brains, and they know about that oily rag you threw in the trash in 1989. Pretty scary. No, really, we didn't X-ray their brains. But we did read their book so we know what they may be looking for and what's on their minds in general. In this issue, we thought we'd share some of this government intelligence with our readers.

The inspector looks at your overall safety program; within this scope, management commitment to safety, hazard identification and abatement, and safety enforcement. The inspectors will also talk to your employees. They will ask carefully designed questions to figure out if your safety program is really working or if it's sleeping on the job.

Questions might include:

• What do you do?
• What equipment and tools do you use?
• How were you trained?
• How do you learn safety rules?
• Are rules enforced for everybody?
• What do you do in the event of an accident?
• How do you report problems and suggestions?
• Is your job safe?
• Is your equipment safe?

There are no surprises here, so all you have to do is maintain reasonable, common sense safety standards and make sure everybody is playing by the rules.

Treat yourself to another cup of coffee and be aware that some of the inspectors are citing employers for use of disinfectants.

Some inspectors say that hazard communication training is not adequate for employees exposed to pesticides, germicides, and insecticides.

Some inspectors feel that the general training of employees on the safety and health hazards of their job is not as effective as establishing specific employee training requirements.

To prepare for an inspection, compliance officers become familiar with the history of the establishment, the operations and processes in use, and the standards most likely to apply. They gather all equipment necessary to test for health and safety hazards.

When OSHA inspectors arrive, they display official credentials and ask to see the employer. Employers should always insist upon seeing the compliance officer's credentials, which can be verified by the nearest OSHA office.

Opening Conference: The compliance officer will explain the nature of the visit, the inspection's scope, and the applicable standards.

Information on how to obtain copies of the OSHA regulations will be furnished. An authorized representative of the employees, if any, has the right to accompany the compliance officer. The compliance officer will consult with a reasonable number of employees.

Walk-Around Inspection: After the opening conference, the compliance officer and the representatives go through the workplace inspecting for workplace hazards. When talking with workers, compliance officers will try to minimize work interruptions.

The compliance officer will discuss any apparent violations noted during the walk-around and will offer technical advice on how to eliminate hazards.

Closing Conference: The compliance officer reviews any apparent violations with the employer and discusses possible methods and time periods necessary for their correction. The compliance officer explains that these violations may result in a citation and a proposed financial penalty, describes the employer's rights and responsibilities, and answers all questions.

Date:

Date of Next Inspection:

Remarks

Accepted by Safety Manager

Signature

Date

Employer Postings and Recordkeeping (cross out any items that are not applicable):

Recordkeeping:

Workplace Safety and Hazard Communication Program (cross out any items that are not applicable):

Workplace Safety

Written Safety Program:

• Is the program effective?
• Is the responsible person identified?
• Is the program enforced?

1. Hazard Identification System
2. Corrective Action Program
3. Safety Training System
4. Supervisor Training
5. Employee Motivation System
6. Emergency Response Plans

Hazard Communication:

• Is there a written hazard communication program?
• Are there hazardous material handling procedures?
• Is there a list of all hazardous substances used in the workplace?
• Are all required Material Safety Data Sheets (MSDS) checked and available?
• Is there a policy for labeling?
• Is there employee training including:

• Is each container for a hazardous substance (i.e. vats, bottles, storage tanks) labeled with product identity and a hazard warning (communication of the specific health hazards and physical hazards)?

1. Employee hazardous material exposure documentation
2. Flammable and combustible materials procedures
3. Ventilation procedures

Fire Protection and Emergency Response (cross out any items that are not applicable):

• Fire protection
• Fire prevention plan
• Control of hazards and ignition sources
• Employee training
• Fire department communication
• Alarm system appropriate and tested regularly
• Fire doors operating
• Automatic sprinkler system maintained
• Fire extinguishers accessible
• Extinguishers serviced

Emergency Response:

• Earthquake plan
• Flood plan
• Other natural disasters
• Evacuation plan
• Bomb threat
• Civil unrest
• Criminal activities
• Hazardous material leak or spill
• Environmental hazard

Initial response participation follow-up

• Environment (cross out any items that are not applicable):
• General environment
• Clean worksites, general housekeeping
• Proper removal and storage of scrap, debris and waste
• Combustible, metallic, and/or corrosive dust removal
• Burners with prevent flow if pilots fail
• Adequate sanitary toilets and washing facilities
• Adequate illumination
• Other

Walkways:

• Aisles and passageways clear, free of obstructions
• Appropriately marked 'Exit' and 'No Exit'
• Non-slip materials as needed
• Holes and defects repaired promptly and properly
• Clearance when motorized equipment is operating
• Immediate clean up of spills
• No sharp projections in walkways
• Changes of direction and elevation marked
• Adequate headroom
• Standard guardrails, covers, grates, etc.
• Bridges over conveyers and hazards
• Glass and skylights appropriate
• Openings provided with appropriate fire resistant doors or covers and self-closing features as needed

Stairways:

• Standard stair rails 30 - 34' high, 1.5' from wall, capable of withstanding 200 lbs.
• Stairways 22' or more wide, 6'6' overhead clearance, 30 to 50-degree angle
• Noise reduction as needed
• Uniform risers
• Adequate barriers and warnings where traffic areas impinge.

Medical Service/First Aid (cross out any items not applicable):

• Medical/first aid
• Local medical facilities
• Employee qualified to render first aid
• Health consultation available
• Emergency phone numbers posted
• First aid kits
• First aid kit inspection and approval
• Special measures such as emergency showers
• Other

Equipment Safety:

• Lockout /tagout system and training
• Process safety management
• Confined space program -

Protective Equipment (cross out any items not applicable):

• Goggles or face shields
• Gloves, aprons, and shields
• Hard hats
• Foot protection
• Emergency respirators, and fit testing
• Eye wash facilities and showers
• Noise protection
• Protective clothing and equipment
• Training in PPE use
• PPE maintenance in good order
• Other

Flammable and Combustible Materials Handling (cross out any items not applicable):

• Are combustible scrap, debris and waste materials stored in covered metal receptacles and removed from the worksite promptly?
• Is proper storage practiced to minimize risks of fire and spontaneous combustion?
• Are approved containers used for the storage/handling of flammable and combustible liquids?
• Are all connections on drums and combustible liquid piping, vapor and liquid tight?
• Are all flammable liquids kept in closed containers when not in use?
• Are bulk drums of flammable liquids grounded and bonded to containers during dispensing?
• Do storage rooms for flammable and combustible liquids have explosion-proof lights and mechanical or gravity ventilation?
• Is liquefied petroleum gas stored, handled and used in accordance with safe practices and standards?
• Are liquefied petroleum gas storage tanks guarded to prevent damage from vehicles?
• Are all solvent wastes and flammable liquids kept in fire-resistant, covered containers until they are removed?
• Is vacuuming used whenever possible, rather than blowing or sweeping combustible dust?
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