SAFETY BLOG

OSHA Inspections

As safety consultants, our job is to help employers and employees understand the OSHA inspection process and inform them of their rights during these inspections.

OSHA Inspections

• OSHA can:
• inspect during regular working hours and at other reasonable times, and within reasonable limits and in a reasonable manner.
• can privately question any employee they see fit to question.
• inspect any place of employment, and all pertinent conditions, structures, machines, apparatus, devices, equipment and materials therein.
• take environmental samples or obtain photographs related to the purpose of the inspection, and employ other reasonable investigative techniques.
• notify the employer before leaving that a temporary restraining order will be petitioned for an imminent danger threat, and require the employer to post a  sign in the hazard area notifying employees of the threat if threat is not immediately abated.
• apply to the nearest federal district court for a temporary restraining order to shut down or halt operations.
• OSHA cannot:
• conduct a warrantless inspection without consent from the employer.
• refuse to be accompanied throughout the inspection process by a representative of the employer or establishment.
• make public any information gathered during the inspection process relating to trade secrets of the employer.
• shut down any employer or operation without a temporary restraining order from a federal court.
• OSHA Inspection Priorities:
1. Imminent danger
2. Fatalities and catastrophes
3. Programmed high hazards
4. Follow up inspections

 Employer Rights

• Employers have a right to:
• seek advice from OSHA.
• require inspectors to furnish identification and warrant.
• have an opening and closing conference.
• accompany inspector during inspection process.
• contest citations.
• take an active role in the development of safety standards.
• have trade secrets kept confidential.

 Inspection Process

• Opening Conference:
• explains purpose and scope.
• employer provides a representative to accompany inspector.
• Documents reviewed:
• OSHA 300 log and 301 forms.
• OSHA poster.
• safety programs
• mechanical power press maintenance and inspection records.
• Safety inspection and walk-through:
• examines site, processes, operations, equipment, machines, devices, etc. for OSHA compliance.
• Closing conference:
• no citation issued at this time.
• briefs employers on conditions found.
• informs employer of whether citations will be issued and the employers right to appeal such citations.

 Always consult OSHA and federal standards for more details.

Be safe out there!

Starting a Personal Protective Equipment program for general industry?  Follow the following checklist to ensure your program is OSHA compliant and your related trainings are efficient.

PPE Program and Training Checklist:

1. Identify (in writing) steps taken to assess potential hazards in workplace.
2. Identify appropriate PPE selection criteria.
3. Identify how to train employees on use of PPE:
1. What PPE is necessary.
2. When PPE is necessary.
3. How to Properly inspect PPE.
4. Donning and adjusting PPE.
5. Doffing PPE.
6. Limitations of PPE.
7. How to care for and store PPE.
4. Identify how to assess employee understanding.
5. Identify how to enforce use of PPE.
6. Identify how to provide medical exams.
7. Identify how and when to evaluate PPE program.

Contractors need to understand their role in ensuring construction safety.  Construction sites are dynamic in nature, and generally are plagued with multiple serious health and safety hazards.  All employees are entitled to a sanitary and non-hazardous work environment.  OSHA's 1926 subpart C defines the basic responsibilities of the construction contractor.  The following is a list of basic safety standards that contractors must meet to increase safety on the job site.

• Initiate and maintain programs as necessary to maintain safe work environment
• Provide for frequent and regular inspections of job sites, materials, and equipment to be made by a designated competent person
• Machinery, tools, materials, or equipment that is out of compliance must be identified by tagging as unsafe, locking the controls to render them inoperable, or physically taking them out of service
• Shall permit only those employees qualified by training or experience to operate equipment and machinery
• Instruct each employee on how to recognize and avoid unsafe conditions
• Inform employees of the regulations applicable to his/her work environment
• The goal is to eliminate or control all known hazards through employee instruction
• Instruct employees on hazardous or harmful chemicals and how to protect themselves
• Make employees aware of harmful plants and animals
• Make first aid accessible
• Require personnel to wear appropriate PPE
• Instruct on confined or enclosed spaces, the hazards, necessary precautions, and comply with regulations pertinent to that condition
• Instruct employees on safe handling and use of flammable liquids, gases, and toxins

Contact a reliable safety consultant to get more details on how to initiate these basic safety programs.

Contractors and construction workers must realize the extreme hazards of excavating.  OSHA reports that trenching and excavating is the most hazardous operation in the construction field.  According to the American Society of Civil Engineers, there are more than 65 fatalities per year associated with trench and excavation work.  Most accidents occur in trenches 5-15 feet deep.  Contractors must use precise planning before breaking ground on any job site.  The following factors must be considered when choosing the appropriate trench safety system;

• Soil classification
• Depth of cut
• Water content of soil
• Changes in stability due to weather and climate
• Other operations taking place in vicinity

In order for a contractor to choose the correct trench safety system, they first must be fluent with OSHA's Subpart P of 29 CFR part 1926.  The standards stated in this text provide the groundwork for excavation safety.  It is important to note that house foundations and basement excavations are exempt from the standards.  highlight's of this standard include;

• Always contact utility companies before breaking ground
• A means of egress shall be provided in excavations 4 ft. deep or more so as to require no more than 25 ft. of lateral travel to nearest egress
• No employees are allowed under loads handled by lifting or digging equipment
• Atmospheric testing must be undertaken in trenches 4 ft. deep or more if there exists a potential for a hazardous atmosphere
• Emergency rescue equipment shall be available where hazardous atmospheres exist
• All spoil and materials piles must be placed at least 2 ft. away from edge of excavations
• Employees working in excavations 5 ft. deep or more shall be protected from cave-ins by adequate protective systems outlined in OSHA's standard

The appendix section of Subpart P provides the technical data for trench safety systems.  Contact a trench safety specialist for further details on protective systems, implementation, and associated standards.

Safety is always the first priority on a construction site.  Hazards develop as soon as ground breaking operations begin.  Implementation of a sound trench and excavation safety training program is the first step in protecting your employees.  Designate a competent person to evaluate all excavations and use hazard assessment techniques to determine the identity of appropriate safety systems.  Evaluate trench safety on a daily basis using the stability factors mentioned earlier in this article.  Finally, when in doubt, never put someone in the trench!

Anytime you dig, you are excavating the dangers down below!  Do not become a statistic.  Educate yourself on trench and excavation safety.

Safety trainings in Ohio are becoming more common as liabilities have increased throughout the years.  Ohio is listed as a federal OSHA state and uses OSHA standards as their own.  More and more contractors in the State of Ohio are requiring their subcontractors to have OSHA safety training certificates to perform work on their projects.  These certificates equal a reduction in liability insurance and potential safety related problems for the contractors.  If you are a company that is engaging in a lot of work in Ohio, chances are good that you will be asked if your employees are OSHA safety certified.

Many contractors will require your base employees to have OSHA 10 certification and your management staff to have OSHA 30.  The 10 hour certification is a general introduction to the identification and abatement of hazards in the workplace, and the 30 hour certification is a more detailed examination of hazards and the OSHA standards that regulate and protect workers from them.  So the question arises, who can train our employees to get this safety certification?

You will not have to look far to find a OSHA Outreach trainer, but you will want to get an idea of how the information is presented.  Most people who sit through these trainings will tell you that it was the most boring training they have ever endured in their life.  Listen folks, it does not have to be that way.  To make this training a rewarding experience for your employees, you should be asking safety trainers for their experience and methods before deciding on which trainer to use.

Ask them if they have any personal experience mitigating workplace accidents or injuries, and whether or not they have been responsible for the safety of others in a workplace.  Generally, trainers who have been responsible for others or have dealt with workplace accidents tend to have more passion for the importance of safety.  That passion leads to more commitment to the education of employees.

Lastly, ask them how the information is conveyed to the trainees.  If the trainer says, "I use a power point presentation", that should raise a red flag to mean that they are going to just flip through slides and read what is on them.  Look for trainers that use multimedia and group activities in their trainings.  A mixture of power points, videos, case studies, group worksheets, discussions, and reenactments is an excellent way to convey important safety information and all the while keeping the audience engaged, thinking, and involved.

Bottom line, boring safety trainings identifies safety as a burden in the workplace.  Your employees will feel as though it is a burden that they are forced to carry.  Remember, being proactive instead of reactive in regards to safety is what you should be striving for.  Locating safety trainers that are not only experienced but entertaining as well, is a proactive step in lightening the load of safety in the workplace.

Webster defines integrity as: 1. completeness 2. unimpaired condition; soundness 3. honesty, sincerity, etc. What a great word.  Today, words such as integrity and sincerity are used as catch phrases or ad words, but where is the substance or meaning.  The essence of words such as these are not reflected by the people using them.

American businesses used to pride themselves on the meaning of integrity.  If you stopped to get fuel fifty years ago, someone would pump your fuel, wash your windows, check under the hood, and put air in your tires.  Today, we are grossly overcharged for fuel, we pump it ourselves, we're lucky to have window washing fluid in the bucket to wash our windows with, and we have to pay for air.  See a problem here?  Our needs as clients have been dropped as a priority for successful businesses.  This is only one example being used as a model.  Nevertheless, most American businesses operate under these very same principles.  It should not be surprising that there is no consumer trust in American business these days.

"The client knows best" is a phrase that most people cannot remember anymore.  Well, it's time to jar their memories.  What do you want your business reputation to stand for?  Integrity?  If so, its time to get back to putting the client first.  Go the extra mile.  Include extra services at no charge.  Talk to your clients on a regular basis.  Make them feel like they are your only client.  In the words of Jerry Maguire; "less clients and more personal attention". 

Ask yourself, where have all of our business heroes gone?  I think they still exist, but have been silenced by cost-cutting practices, corporate influence, and the devastating current American business trend of maximizing profit margins.  Centering on your clients will reinvest their trust in your company, thus securing your client base, and eventually increase your word-of-mouth leads.  It is up to every American business owner to personally take the steps to reinvent the client-based business.  Once this trust is established, the health & safety of American business will be secured. 

A progressive safety firm has found a new breed of safety consultants.  Heroic Safety Soltuions has added safety forces personnel such as firemen, paramedics, and police officers to its arsenal of safety trainers.  These are people who deal with workplace accidents and injuries everyday.  They are hard working Americans that have won the hearts of our communities.  Who better to relate to and train our workforce.  Every city in the United States is stocked with these professionals, and everyone of them has expertise and certifications in different areas of safety.  The trial run has been extremely successful.  Employees trust and rely on the reputations of these professionals.  They keep the attention of their audiences by using real life stories of accidents and tragedies in their trainings, which employees seem to love.  The days of boring safety trainings led by "the snot-nosed college kid" are gone.  Enter Heroic Safety Trainers.

Heroic Safety Solutions