Surviving the OSHA Audit! Presented By: David A. Casavant rCFM, LEED AP Authorized OSHA Trainer The Sustainable Workplace Alliance david@sustainablewp.org

Good News / Bad News In a typical year OSHA . . . . Issues over $40 Million in Fines Logs over 87,000 citations (67,000 cited as "serious“) $170 billion a year on costs associated with occupational injuries and illnesses Lost productivity from injuries and illnesses costs companies $60 billion each year! Liberty Mutual

REMEMBER: If something is predictable, its manageable. . . OSHA’s Three Stage Inspection Program Opening Conference Inspection Tour Closing Conference REMEMBER: If something is predictable, its manageable. . .

Plus One More Reduction Opportunity! OSHA Appeals Process Informal conference Good faith: 25% Size of business: 10%–70% Good history: 10% Quick Fix: 15% 1 – 10 = 70% reduction, 11 – 25 = 60% reduction, 26 – 100 = 30%, 101 – 250 = 10% Plus One More Reduction Opportunity!

Establishment Search www.osha.gov/pls/imis/industry.html

Prohibited Uses of Flexible Cords 1910.305(g)(1)(iv)(A)-(F) As a substitute for the fixed wiring of a structure; Where run through holes in walls, ceilings, or floors; Where run through doorways, windows, or similar openings; Where attached to building surfaces; Where concealed behind building walls, ceilings, or floors; or Where installed in raceways, except as otherwise permitted in this subpart. Quiz Question 1910.305(g)(1)(iv) Unless specifically permitted otherwise in paragraph (g)(1)(ii) of this section, flexible cords and cables may not be used:1910.305(g)(1)(iv)(A) As a substitute for the fixed wiring of a structure;1910.305(g)(1)(iv)(B) Where run through holes in walls, ceilings, or floors;1910.305(g)(1)(iv)(C) Where run through doorways, windows, or similar openings;1910.305(g)(1)(iv)(D) Where attached to building surfaces; Concealed behind or attached to building surfaces Substitute for fixed wiring Run through walls, ceilings, floors, doors, or windows 133

GFCI Protection 1910.304(b)(3)(ii)(A) Receptacle outlets (including cord sets) that are not part of the permanent wiring of the building shall have ground-fault circuit-interrupter protection for personnel when doing construction-like activities. 1910.304(b)(3)(ii)(A) All 125-volt, single-phase, 15-, 20-, and 30-ampere receptacle outlets that are not part of the permanent wiring of the building or structure and that are in use by personnel shall have ground-fault circuit-interrupter protection for personnel. Note 1 to paragraph (b)(3)(ii)(A) of this section: A cord connector on an extension cord set is considered to be a receptacle outlet if the cord set is used for temporary electric power. Note 2 to paragraph (b)(3)(ii)(A) of this section: Cord sets and devices incorporating the required ground-fault circuit-interrupter that are connected to the receptacle closest to the source of power are acceptable forms of protection.

Prohibited Use of Flexible Cord 1910.305(g)(1)(iv)(A)-(F) Flexible cords may not be attached to building surfaces

GFCI in Wet Location 1910.305(j)(2)(ii) A receptacle installed in a wet or damp location shall be suitable for the location. NOTE: According to the National Electric Codes (NEC/NFPA 70), GFCI protection is required on all outlets in kitchens along the counter, in bathrooms, pool and shower facilities supplied with 110 volt power. (Six foot proximity)

Open Junction Boxes – Server Room 1910.303(b)(7)(i)Unused openings in boxes, raceways, auxiliary gutters, cabinets, equipment cases, or housings shall be effectively closed to afford protection substantially equivalent to the wall of the equipment. 131

Open Junction Boxes 1910.303(b)(7)(i)Unused openings in boxes, raceways, auxiliary gutters, cabinets, equipment cases, or housings shall be effectively closed to afford protection substantially equivalent to the wall of the equipment. 131

1910.305(b)(2)Covers and canopies. All pull boxes, junction boxes, and fittings shall be provided with covers approved for the purpose. If metal covers are used they shall be grounded.

Nominal voltage to ground Minimum clear distance for condition2 3 Condition A Condition B Condition C m ft 0-150 151-600 10.9 10.9 13.0 13.0 10.9 1.0 13.0 3.5 0.9 1.2 3.0 4.0 Condition A -- Exposed live parts on one side and no live or grounded parts on the other side Condition B -- Exposed live parts on one side and grounded parts on the other side Condition C -- Exposed live parts on both sides

Required Inspections 1910.157(e)(2) Portable extinguishers shall be visually inspected monthly (see example on right side) 1910.157(e)(3) The employer shall assure that portable fire extinguishers are subjected to annual maintenance

Questions?

david@sustainablewp.org David A. Casavant, Authorized OSHA Trainer Executive Director - The Sustainable Workplace Alliance david@sustainablewp.org