How to survive an OSHA inspection Presented to SCRA By Jim Stanley

Two challenges 1.The ongoing challenge to insure the safety of the workforce. 2.The new challenge of greatly increased OSHA enforcement.

Two challenges Dealing with the second challenge doesn’t always help insure success with the first.

The ‘New’ OSHA More ‘egregious’ citations being issued – resulting in megafines.

The ‘New’ OSHA Penalties increasing overall, including for non-egregious citations. 215 cases in where a company was fined more than $100, up 31%.

The ‘New’ OSHA New authority to issue citations on multi-employer worksites.

The ‘New’ OSHA Creation of a ‘Severe Violators Enforcement Program.’

The ‘New’ OSHA Crackdown on recordkeeping.

The ‘New’ OSHA Proposal to require every employer to have an Injury and Illness Protection Program – I2P2.

The ‘New’ OSHA Requirement that training be presented in a manner that employees can understand.

The ‘New’ OSHA Increased pressure on states that have their own safety enforcement agencies.

Common violations at crane and rigging or transportation sites

How to be successful with OSHA Preparations before an inspector ever arrives What to do during an inspection

Preparations before an inspector ever arrives 1) Make sure all documentation is accurate and written health and safety program is current.

Preparations before an inspector ever arrives 2) Make sure you have conducted all training required under your program and by federal regulation.

Preparations before an inspector ever arrives 3) Analyze where your accidents and illnesses are happening and put corrective action in place.

Preparations before an inspector ever arrives 4) Conduct a mock OSHA audit to identify weak spots.

Preparations before an inspector ever arrives 5) Go beyond OSHA requirements and promote a culture that emphasizes safety. Conduct motivational training. (More on this in a few minutes)

What to do during an inspection 1) Have a manager designated in advance to be a representative to OSHA during an inspection. Inspections typically are on a surprise basis.

What to do during an inspection 2) Take advantage of the opening conference, which typically occurs right after an inspector arrives, to discuss what will happen during the inspection and understand its scope.

What to do during an inspection 3) The company representative should always accompany the OSHA inspector during the walk-around inspection.

What to do during an inspection 4) Inform non-supervisory workers that they can speak or not speak with the inspector as they choose. Give them an idea of the kinds of questions likely to be asked.

What to do during an inspection 5) Don’t be afraid to ask questions during the closing conference at the end of the inspection.

The best thing you can do to get a good inspection …

Make safety part of your culture Time, effort, comfort and peer pressure are the foremost reasons employees commit unsafe acts when they know better but don’t do better.

Make safety part of your culture There are three key pillars of an effective safety program: 1. Commitment from senior management

Make safety part of your culture 2. Active implementation of a formal safety program led by mid-management (i.e. foreman, superintendent)

Make safety part of your culture 3. Employee involvement and practice through example and demonstration, not directives

Make safety part of your culture There are three types of accountability: 1. Personal accountability 2. Peer accountability 3. Management accountability

Make safety part of your culture How a company demonstrates its commitment

Make safety part of your culture Zero tolerance

Make safety part of your culture Employers must create a system of accountability that includes: ■ Thorough training ■ Strong policy ■ Documentation ■ Accountability to follow through with safety rules

Make safety part of your culture Emphasizing what’s really important

Make safety part of your culture “What are the top three most important things in life?” Common answers: 1. Family 2. Faith 3. Health

Preparing an Effective Safety Program Safety begins first with top management: focus on visual concepts, not just words.

Preparing an Effective Safety Program Create a program that makes sense to management and workers.

Preparing an Effective Safety Program Identify where issues exist and implement a program that serves best.

Preparing an Effective Safety Program Fully understand the responsibility and requirement to wear personal protective equipment.

Preparing an Effective Safety Program Encourage employee involvement and feedback.

Preparing an Effective Safety Program Develop a safety committee with the authority to create and implement changes.

Preparing an Effective Safety Program Select an employee from the workforce as a fulltime safety coordinator with the responsibility of making safety changes without disciplinary authority.

Summary

Questions

James Stanley, President Office: Cell: Website: Read our blog Sign up for our newsletter on our