The BWC Division of Safety & Hygiene’s OSHA On-Site Consultation Program

Objectives o Understand the OSHA On-Site Consultation Program process – start to end o Debunk the myths about the OSHA On-Site Consultation Program

OSHA On-Site Program Overview o 90% federally funded o 10% state funded - Ohio Bureau of Worker’s Compensation On-site consultants work with small, high-hazard employers to address the employer’s overall safety and health management system and to assist them in ensuring a safe and healthful workplace for their employees.

Industrial Hygiene Services o Conduct noise surveys o Conduct air monitoring o Ventilation assessments o Provide advice as to the proper industrial hygiene/engineering controls

OSHA On-Site Consultation o Similar to a federal OSHA inspection Opening conference Walk-through Closing conference A written report that summarizes the results of the visit

Opening Conference o Rights and obligations explained Hazard abatement deadlines Interim protection o Full service consultation Facility walk-through Written program review Review of OSHA recordkeeping (300 logs) Safety and health management assessment

Safety and Health Management Review o Conduct a safety and health program/policy review Hazard anticipation and detection Hazard prevention and control Planning and evaluation Administration and supervision Safety and health training Management leadership Employee participation

Walk-Through o Employee participation For union shops, opportunity to participate in walk-through is required. o Discussion with employees Required for all visits To help assess safety and hygiene management To help assess the extent of hazards

Walk-Through o Scope of visits Full service - look at all processes Limited service - look at specific operations o Informal training

Hazards Identified o Imminent danger situation Abated immediately o Serious finding Develop and agree to a reasonable plan and schedule to eliminate or control that hazard o Other-than-serious Should be corrected, but abatement documentation not required o Regulatory o Other findings and recommendations

Closing Conference o Review findings o Due dates o Methods of abatement o Interim protection o Follow up visits o Training visits o Offer formal training

After the Visit o Written report Recommendations on correcting and improving safety and health program. o Explaining the findings o Confirming abatement periods

After the Visit o Follow-up visits available o Other assistance available o OSHA requires hazard abatement of all serious hazards o If not abated, referral to federal OSHA for potential enforcement action is possible

Federal OSHA o Referral to OSHA Imminent danger not abated immediately Serious hazards not abated by due date o Enforcement inspection No consultation until citations are final Usually takes priority over consultation o Programmed inspections Consultation takes priority LEP – Local Emphasis Program NEP – National Emphasis Program SST – Site Specific Targeting

On-Site Consultants Will: o Suggest general approaches or options for solving a safety or health problem; o Identify kinds of help available, if needed; o Help recognize hazards in the workplace; o Provide a written report summarizing findings.

On-Site Consultants Will: o Assist in developing or maintaining an effective safety and health program ; o Provide awareness training and education for employees.

On-Site Consultants Will Not: o Issue citations or propose penalties for violations of OSHA standards; o Routinely report possible violations to OSHA enforcement staff; o Guarantee that your workplace will “pass" an OSHA inspection.

Exemptions and Deferrals o SHARP (Safety and Health Achievement Recognition Program) exemption o Pre-SHARP inspection deferral o SST deferral

Safety and Health Achievement Recognition Program (SHARP) o Parallels Federal OSHA’s Voluntary Protection Program (VPP) o A company must work on an on-going basis with the OSHA On-Site Consultation Program and demonstrate an exemplary safety and health program. o Provides an exemption from general schedule inspections

Pre- SHARP Inspection Deferral o Companies that are working toward SHARP status but are not quite ready o One time o Up to 18 months o Action plan

Site Specific Targeting (SST) Deferral o Must request and schedule a full service visit, safety and health o Deferral lasts 90 days from the date that the visit is actually requested. o Requires notification to OSHA that the employer has a visit scheduled o Cannot be extended beyond 90 days o List changes year to year

Myths About the OSHA On-Site Consultation Program o The Program routinely notifies OSHA to conduct a compliance inspection. o Federal OSHA knows which companies have used On-Site Consultation Program services. o Abatement of serious hazards are not required. o We provide site-specific training to employers.

Why Bother?

To Get Started: o Phone Call – State Wide (Automated) o