|
AFFILIATIONS
|
 PREPARING
FOR AND SURVIVING AN
OSHA INSPECTION
by Sandra Noble, President
Noble & Associates Consulting,
Inc.
Avoid the cost and the pain of an OSHA Inspection. Like a good Boy Scout
- "Be prepared". The goal is for employers to pass the compliance test
and get the merit badge of approval from OSHA.
The primary responsibility of the Occupational Safety and Health
Administration (OSHA) is to develop and enforce health and safety
standards that protect workers in the workplace. It has mandatory power
to audit organizations for compliance of health and safety standards.
OSHA conducts workplace inspections to make certain that employers are
complying with the standards and providing a safe and healthful
workplace.
OSHA inspectors, called compliance and safety officers, carry out these
inspections/audits. These may be carried out due to accidents,
fatalities, situations of imminent danger, complaints and referrals or
as a follow-up investigation. An OSHA audit can be a tedious and
stressful experience for employers since the agency is empowered to
impose penalties on those who are in violation of the standards. This is
particularly true for small businesses that may not have the wherewithal
to be in full OSHA compliance.
Generally, an employer who takes proactive action (and the associated
pains) to try and adhere to mandated requirements will fare much better
during such OSHA inspections. A little known fact for many employers is
that compliance officers normally research the history of a worksite
before an inspection. Therefore it pays to work with the inspectors and
answer questions fully and honestly, rather than adopt stalling tactics.
Actions like insisting on an inspection warrant, to buy time, can turn
out to be counterproductive in the end.
Every workplace is unique; no universal formula can be prescribed for
negotiating an OSHA audit unscathed. However, attention to some basic
details can help immensely:
First, having an effective safety and health program which lays down the
policies, procedures and practices for protection against occupational
safety and health hazards helps to develop the proper mindset. Depending
upon the type industry and the complexity of operations, these programs
may even include a Processes Safety Management (PSM) program mandated by
the 29 CFR 1910.119 OSHA Standards. A written program should be
communicated to all employees.
Second, coaching employees on health and safety, including OSHA
compliant training, should be routine. Proper training is necessary to
insure that workers understand potential hazards as well as practice
safe working methods.
Third, it is important for companies to stress employee participation in
safe practices. Active employee involvement can greatly enhance
compliance to OSHA standards.
Fourth, it is imperative that businesses have a written hazard
communication program. This is particularly important in industries
handling hazardous chemicals. The complexity of the program will
obviously depend upon the specific needs of the worksite. It may range
from a simple collation of information from Material Safety Data Sheets
(MSDS), to a comprehensive OSHA mandated program in line with the 29 CFR
1910.1200 Standard.
Fifth, periodic self inspections and compliance audits will help to
identify violations and allow corrective action to be taken. Earlier
cases of accidents or injuries, if any, can also be analyzed for
possible preventive measures. This will minimize the likelihood of being
cited for violations during OSHA audits.
Record keeping is one of the most important tools for providing proof of
a company’s efforts to comply with an OSHA inspector. The scope of
documentation is wide and the more accurately records are maintained;
the better it is for audits. Examples of relevant documentation would be
accident reports, injury and illness reports, exposure records (hazmat
exposure, noise exposure, etc where applicable), past inspections and
action-taken reports, as well as employee training records.
All these steps will lessen the stress of an OSHA inspection and reduce
the odds of receiving citations and penalties. As an OSHA fact sheet
states, “OSHA’s primary goal is correcting hazards and maintaining
compliance, rather than issuing citations or collecting penalties.”
-------------------------------------------------------------------------------------------------------------------------
Get
OSHA Regulation Explained For Business Owners &
Managers
Sandra Noble MBA, CPIM, Six
Sigma, DCFS,
CDP, is president of
Noble & Associates Consulting which specializes in I.T. Needs /
Strategy Assessments, unbiased Software Selection assistance, and curing
Post Implementation Distress™. We also have full life cycle
implementation expertise in SAP, Oracle and other enterprise-wide
software solutions.
Reducing the
STRESS
of Software
Implementations Worldwide!
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Copyright © 2007,
Noble & Associates Consulting, Inc.
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