OSHA UPDATE PANEL Monday, October 3, 2011 Kevin Kilp, Area Director, Harrisburg Jean Kulp, Area Director, Allentown Mark Stelmack, Area Director, Wilkes-Barre Rev:30 Sept 2011

Overall Agenda: Inspection Targeting Regulatory Agenda Updates Website Tools Where Do I go for help Questions and Answers Administrative Penalty Changes

REGION III Regional Administrator: Deputy Regional Administrator: Kurt Petermeyer

Pennsylvania OSHA Area Directors Mark Stelmack Theresa Naim Jean Kulp Albert D'Imperio Kevin Kilp Robert Szymanski Rev: 14 Aug 2008

How Does OSHA Decide Who to Inspect? OSHA cannot inspect all workplaces it covers each year. The agency seeks to focus its inspection resources on the most hazardous workplaces. 6

DIRECTIVE NUMBER: CPL 02-00-148 http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-00-148.pdf

OSHA INSPECTIONS Inspection/Investigation Types Inspection Priorities: Unprogrammed inspections: Imminent Danger Catastrophes and Fatal Accidents Complaints and Referrals Follow-up Inspections

OSHA INSPECTIONS Inspection/Investigation Types Inspection Priorities: Programmed Inspections: Site-Specific Targeting (SST), Construction Scheduling for Maritime Inspections Special Emphasis Programs (SEPs). National Emphasis Programs (NEP), Regional (REP) & Local Emphasis Programs (LEP), Other Special Programs.

Site-Specific Targeting 2011 (SST-11) DIRECTIVE NUMBER: 11-03 (CPL 02) EFFECTIVE DATE: September 9, 2011 http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-11-03.pdf Sept 2011

http://www. osha. gov/pls/oshaweb/owadisp. show_document http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=NEWS_RELEASES&p_id=20646

OSHA INSPECTIONS (SST-11) Site Specific Targeting (SST) Comprehensive 3 Categories: Manufacturing Establishments Non-Manufacturing Establishments Nursing and Personal Care Facilities Based upon DART and DAFWII Rates

OSHA INSPECTIONS Site Specific Targeting (SST-11)   Primary Secondary Tertiary Manufacturing Establishments: DART 7.0 5.0 OSA DAFWII 4.0 Discretion Non-manufacturing Establishments: 15.0 14.0 Nursing and Personal Care Facilities (805) 16.0 13.0 11.0

Injury and Illness Recordkeeping National Emphasis Program (RK NEP) DIRECTIVE NUMBER: 10-07 (CPL 02) EFFECTIVE DATE: September 28, 2010 EXPIRES: February 19, 2012 http://www.osha.gov/OshDoc/Directive_pdf/CPL_02_10-07.pdf

https://www. osha. gov/pls/oshaweb/owadisp. show_document https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=NEWS_RELEASES&p_id=16725

Appendix A

Verification of each Recordable Injury and Illness Record Onsite inspection to review CY 2008 and CY 2009 injury and illness records: Medical records Worker’s compensation records Insurance records Payroll absentee records Company safety incident reports Company first-aid logs Alternate duty rosters Disciplinary records pertaining to injuries and illnesses. Note: This includes records stored on and off site.

Example Recordkeeping Citations Failure to : record injuries or illnesses on the OSHA 300 form. record a case correctly adequately describe the location provide a specific description enter the correct number of calendar days not completing or not accurately completing the OSHA 301 complete an OSHA 300A. provide copies of records …

http://www.claimsjournal.com/news/midwest/2010/05/03/109492.htm

Company fined $182,000 for failing to record worker injuries and illnesses OSHA issued eight citations to Company Inc. and fined the company $182,000 for failing to document and report worker injuries and illnesses at its distribution center. OSHA inspectors found that Company had willfully disregarded its responsibilities to comply with OSHA regulations by continuously failing to correctly classify worker injuries or illnesses and not correctly recording the number of days a worker was away from work due to injury or illness. Additional recordkeeping violations found by inspectors included two for which the company had been cited previously. See the for more information on the failure of Company to report worker injuries. Apart from this particular investigation, OSHA has implemented a NEP to assess the accuracy of information on workplace injuries and illnesses recorded by employers.

http://www. osha. gov/pls/oshaweb/owadisp. show_document http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=NEWS_RELEASES&p_id=18261

OSHA INSPECTIONS National Emphasis Programs (NEP) Sept 2011 Combustible Dust Federal Agencies (includes FAA) Flavoring Chemicals (Diacetyl) Amputations (Hazardous Machinery) Hexavalent Chromium Lead Primary Metals PSM Covered Chemical Facilities Petroleum Refinery Process Safety Management Injury and Illness Recordkeeping Shipbreaking Crystalline Silica (follow-ups) Trenching and Excavation

http://www.osha.gov/dsg/combustibledust/index.html

National Emphasis Program (NEP) on Hexavalent Chromium http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-02-076.pdf OSHA Directive CPL 02-02-076, Feb. 23, 2010 OSHA compliance assistance resources:

What is Hexavalent Chromium? Toxic form of chromium metal that is generally man-made Used in many industrial applications primarily for its anti-corrosive properties Can be created during certain “hot” work processes where the original form of chromium was not hexavalent

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Sept 2011