Managing Unannounced Visit from OSHA JOHN P JOHNSON,

Managing Unannounced Visit from OSHA JOHN P JOHNSON,

Managing Unannounced Visit from OSHA JOHN P JOHNSON, MS DIRECTOR OF OCCUPATIONAL SAFETY ELWOOD STAFFING SERVICES, INC. Road Map Why OSHA visits Understanding the inspection process Preparing for the OSHA visit Managing the unannounced visit from OSHA

Top 10 OSHA Citations OSHAs Temporary Worker Initiatives Why OSHA Visits: Inspection Priority Imminent Danger Fatality/Catastrophe Complaint/Referrals Targeted Inspections

Follow-up inspections Understanding the Process Identification Opening conference Walkaround Interviews Closing Conference Identification

CSHO must show credentials OK to follow company policies Right to representation Opening Conference CSHO identifies the purpose of the visit May ask for basic company information Likely to ask for certain files

CSHO will list the scope of the inspection The Walkaround Provide Officer with necessary PPE Officer decides the course of the inspection Accompany the Officer Correct anything you can on the spot Interviews The Officer will most likely conduct interviews

Several employees Several management employees Provide a private area Interviews: Last about 10-15 minutes Generally cover training topics

May cover safety and health questions Closing Conference Inspection Recap Officer reviews general findings with you May ask follow-up questions and summarize expected documents May allow you to ask questions May discuss courses of action the employer may take Results Up to six months to issue citation and proposed penalties

Closing Conference CSHOs shall: Discuss apparent violations Provide, Employer Rights and Responsibilities Following a Federal OSHA Inspection Discuss the strengths and weaknesses of the employers safety and health programs Advise employer and employee of their rights After the Closing Conference CSHO rights up findings and reviews with Area Manager

Determines validity of findings Proposed penalties Sends letter containing citations and penalties to you 15 days to contest Must post citations for employee review Must post intention to contest Preparing for an OSHA Visit Audit your program (where do you stand?):

Whats your safety culture like? Do you have an active, written safety program? Have you completed a JHA? Preparing for an OSHA Visit Audit your program - continued Any past citations? Have they been corrected? Review Injury/Illness history OSHA Logs

Work Comp Loss Runs & Trend Reports Look for trends: Specific equipment Specific process Specific time of day Sidebar How effective is the program? Incidence Rate

Experience Modification Rate IR = (Injuries + Illnesses) x 200,000 Hours Total Hours Worked Preparing for an OSHA Visit Correct deficiencies that the audit identified Continuous improvement Safety Committee Management Employee Preparing for an OSHA Visit

Continuous improvement - continued Lean Manufacturing 5 S Program Six Sigma TQM Systems Safety approach (NASA/Boeing) Near-miss investigations Freebie

Accident Investigation Program (learn from mistakes) Preparing for an OSHA Visit Prepare based on reasons for OSHA visits: Preventing Imminent Danger 3-Es Engineer Educate Enforce Document Regular 3-Es safety audits Safety committee

Management Preparing for an OSHA Visit Prepare based on reasons for OSHA visits continued: Fatality/Catastrophe Do everything to prevent such events Use industry best practices Invite consultants into facility Work Comp Loss Control Consultants

OSHA Consultation Services Preparing for an OSHA Visit Fatality/Catastrophe - continued Process Follow Job Training / Refresher Training Mfg.s Scheduled Maintenance Checks and Service Safety Analyses Develop Train good reporting procedures employees to report problems Document all preventive maintenance efforts

Preparing for an OSHA Visit Complaints/Referrals Encourage employees to report problems Have active suggestion box (Survey Monkey) Involve employees on Safety Committee May need IH testing Consider an incentive program Must not drive injury reporting underground

Encourage reporting of problems for Safety Bucks Preparing for an OSHA Visit Targeted inspections Is your operation on a national emphasis program? Learn about specific inspection instructions This Instruction provides guidance to the Occupational Safety and Health Administration (OSHA) national, regional, and area offices for performing compliance inspections involving OSHAs Combustible dust OSHA Instruction CPL 03-00-008

Hazardous machinery OSHA Instruction CPL 03-00-019 Understand what OSHA focuses on https://www.osha.gov/dep/neps/nep-programs.html https://www.osha.gov/pls/oshaweb/owasrch.search_form? p_doc_type=DIRECTIVES&p_toc_level=2&p_keyvalue=CPL Preparing for an OSHA Visit Follow-up Inspections Were you previously cited by OSHA? OSHA may check for abatement Quickly Notify correct violative conditions OSHA when those condition(s) have been abated

Planning for an OSHA Visit Develop a response plan Create a receptionist plan How to greet inspector Where to have them wait Create an OSHA Team ID Members ID Responsibilities

Planning for an OSHA Visit OSHA Response Team Responsibilities: Understand inspection process Attend opening / closing conferences Accompany the CSHO Record all aspects of the walkaround Planning for an OSHA Visit OSHA Response Team Responsibilities: Take photographs (same photos that inspector takes)

Attend management employee interviews Respond to all document requests Ensure violations are abated Managing an OSHA Visit The CSHO arrives Receptionist greets and receives the CSHO Checks Officers credentials Contacts OSHA office to confirm official business

Briefly explains company policy of notifying corporate Managing an OSHA Visit CSHO arrival continued Receptionist has CSHO wait in predetermined location Lobby Conference Room Receptionist doesnt allow Officer to walk around Managing an OSHA Visit CSHO arrival continued: Receptionist uses phone tree to notify OSHA Team:

CEO Legal Department Safety Director Plant Manager Employee Representative Managing an OSHA Visit Assemble frequently requested documents:

OSHA 300 Log & OSHA 300A Summary and 301 Injury/Illness Incident Report Job hazard analyses Contract Agreements Safety Program (IIPP) Current Reviewed at least annually Accident investigation reports

Sub-contractors Staffing agencies Training records Quizzes/Rosters Computer based training Managing an OSHA Visit OSHA Team (or team member) attends opening conference

Participates in walkaround Makes notes of Officers observations Takes side-by-side photos Asks clarifying questions Corrects violations immediately if possible If possible, participates in mgmt. employee interviews Managing an OSHA Visit

OSHA Team or team member attends the closing conference Asks clarifying questions about potential citations Notes which documents are requested Managing an OSHA Visit Assemble and send any remaining documents as requested If you receive a citation Post the citation

Abate the violation Post abatement results Managing an OSHA Visit OR Decide with legal if you will contest the citation (15 days) Post intention to contest Informal conference Citation deleted or upheld

If upheld, abate the violation Managing an OSHA Visit SPECIAL CASE: Serious, fatal, or catastrophic incidents Remember: Compliance visits after fatal/catastrophic incident: Have all the basic information gathered before you call OSHA Report to OSHA Notify OSHA Response Team Review responsibilities

Pull most requested documents together Top 10 2016 OSHA Citations TOP 10 OSHA Citations 1926.501 Fall protection - 6,929 1910.1200 Hazard communication - 5,677 1926.451 Scaffolds - 3,906

1910.134 Respiratory protection - 3,585 1910.147 Lockout/tagout - 3,414 1910.178 Powered industrial trucks - 2,860 1926.1053 Ladders - 2,639 1910.212

Machine guarding - 2,451 1910.305 Electrical wiring - 1,940 1910.303 Electrical, general requirements - 1,704 Fall Protection 1926.501 Fall protection - 6,929 Sections cited: 1926.501(b)(1) Unprotected sides/edges

1926.501(b)(4)(i) Holes & skylights 1926.501(b)(10) Roofing work on low-slope roofs 1926.501(b)(11) Steep roofs 1926.501(b)(13) Residential construction Hazard Communication 1910.1200 Hazard communication - 5,677 Sections cited:

1910.1200(e)(1) program Implementation of a hazard communication 1910.1200(g)(1) (SDS) Requirement to develop Safety Data Sheets 1910.1200(g)(8) (SDS) Requirement to maintain Safety Data Sheets 1910.1200(h)(1) Training

1910.1200(h)(3)(iv) Explanation of label received on shipping Scaffolds 1926.451 Scaffolds - 3,906 Sections cited 1926.451(b)(1) Working levels of scaffolds shall be fully planked/decked 1926.451(e)(1) access. Cross-braces shall not be used as a means of

1926.451(g)(1) Each employeeshall be protected from 1926.451(g)(1)(vii) Personal fall arrest systems or guardrail systems 1926.452(g)(4)(i) and ends Guardrail systems shall be installed alongsides Respiratory Protection 1910.134 Respiratory protection - 3,585 Sections cited

1910.134(c)(1) Respiratory protection requirement 1910.134(c)(2)(i) Employer must establish respiratory program 1910.134(d)(1)(iii) The employer shall identify and evaluate the respiratory hazards(s) in the workplace 1910.134(e)(1) Medical evaluation for respiratory protection

11910.134(f)(2) Respirator fit testing Lockout/Tagout 1910.147 Lockout/tagout - 3,414 Sections cited 1910.147(c)(1) Energy control program 1910.147(c)(4)(i) General procedures

1910.147(c)(6)(i) Employer shall conduct periodic inspection 1910.147(c)(7)(i) Training 1910.147(c)(7)(i)(A) training Each authorized employee shall receive Powered Industrial Trucks 1910.178 Powered industrial trucks - 2,860 Sections cited 1910.178(l)(1)(i)

Safe operation 1910.178(l)(1)(ii) evaluation Training shall consist of formal, practical and 1910.178(l)(4)(iii) years Evaluation for operators at least once every 3 1910.178(l)(6) Certification

1910.178(p)(1) Truck repair and maintenance Ladders 1926.1053 Ladders - 2,639 Sections cited 1926.1053(b)(1) Portable ladder access 1926/1053(b)(4) designed used only for the purpose for which they are 1926.1053(b)(13)

step The top or top step of a step ladder not used as a 1926.1053(b)(16) With structural defects 1926.1053(b)(22) An employee shall not carry any object or load Machine Guarding 1910.212 Machine guarding - 2,451 Sections cited 1910.212(a)(1)

One or more methods of machine guarding 1910.212(a)(3)(ii) Point of operation 1910.212(a)(5) guarded Exposure of blades less than 7 feet shall be 1910.212(b) Anchoring fixed machinery Electrical Wiring 1910.305 Electrical wiring - 1,940

Sections cited 1910.305(b)(1)(i) Conductors protected from abrasion and openings effectively closed 1910.305(b)(1)(ii) Openings shall be effectively closed 1910.305(b)(2)(i) covers and canopies 1910.305(g)(2)(iii)

Flexible cords and cable (strain relief) 1910.305(g)(1)(iv)(A) Substitute for fixed wiring of structure Electrical, General Requirements 1910.303 Electrical, general requirements - 1,704 Sections cited 1910.303(b)(2) Installation and use 1910.303(g)(1) Space about electrical equipment

1910.303(g)(1)(ii) Working space requirements 1910.303(g)(2)(i) Guarding of live parts 1910.303(f)(2) marked Services, feeders and branch circuits legibly OSHAs Temporary Worker Initiative OSHA Directive April 29, 2013 CSHOs will: Ask

if temporary workers are on-site Determine Inspect if theyve been trained work area for violative conditions Determine Request who provides day-to-day supervision the name and address of the staffing agency Dual Employer Relationship & Responsibilities Between Staffing Agency & Host Employer

Responsibilities should be outlined in Contract Letter of Understanding Dual Employer Relationship & Responsibilities Staffing Agency Responsibilities: Conducts Worksite Evaluation Provides basic training General safety orientation General

hazard communication information Follow-up worksite evaluations Accident investigations Dual Employer Relationship & Responsibilities Host Employer Responsibilities Provide safe & healthy work environment Conduct hazard assessment Notify Staffing Agency of hazards

Select and provide PPE Dual Employer Relationship & Responsibilities Host Employer Responsibilities - continued Provide site- and equipment-specific training Provide supervision Treat temporary worker as own employee Allow Staffing Agency access to facility Follow-up assessments

Accident Investigations OSHAs Provides Recommended practices Background on Temporary Worker Initiative (TWI) Seven TWI Bulletins Temporary Workers Rights Pamphlet Can be found at:

https://www.osha.gov/temp_workers/index.html OSHAs Provides Seven TWI Bulletins: Recordkeeping requirements PPE Whistleblower protection Safety & Health training Hazard communication

BBP Powered industrial truck training Summary We covered Why OSHA visits Understanding the inspection process Preparing for the OSHA visit Managing the unannounced visit from OSHA

Top 10 OSHA Citations OSHAs Temporary Worker Initiatives

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