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OCCUPATIONAL SAFETY INSPECTIONS: HOW TO REPRESENT YOUR CAMPUS DURING THE INSPECTION PROCESS University of Wisconsin System Office of Safety and Loss Prevention Version: July 2012
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2 Overview Version: July 2012 Training goal: To prepare you to handle an occupational safety inspection at your campus Steps: Review the rules for the safety inspection process Explain the inspection visit Post-inspection Regulatory Safety Inspections
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3 Version: July 2012 Supplementary Material Checklist for DSPS Occupational Safety Inspections Links to other information at: http://web.uwsa.edu/oslp/ehs/occupational-safety/misc-safety/enforcement/
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4 Rules for the safety inspection process Version: July 2012 Regulatory Safety Inspections
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5 Safety regulation on campus Version: July 2012 Public employee safety enforced by Wisconsin Department of Safety and Professional Services Adopted most of OSHA regs See also Statute, Administrative Code Student employees covered while working Regulatory Safety Inspections
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6 Safety regulation on campus Version: July 2012 Regulatory Safety Inspections Contractor employee safety: OSHA Lead paint, asbestos: DHS, SPS, OSHA Other agencies: DOT, EPA, DEA
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7 Dept. of Safety and Professional Services Version: July 2012 Regulatory Safety Inspections
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8 Advance notification Version: July 2012 Regulatory Safety Inspections Inspections Without advance notice
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9 Why does an inspection occur Version: July 2012 Regulatory Safety Inspections Inspections are created by: Complaint DWD referral
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10 When/how should inspections occur? Version: July 2012 Regulatory Safety Inspections Inspectors have statutory authority to: Enter without delay and at reasonable times Inspect and investigate the workplace: during regular working hours at other reasonable times Campuses have the right to expect Inspection conducted in reasonable manner, within reasonable limits
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11 Confidentiality Version: July 2012 Regulatory Safety Inspections Names of employees filing a request for inspection can be kept confidential
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12 Participation in inspection Version: July 2012 Regulatory Safety Inspections A campus management representative and a public employee representative must be allowed to participate in the inspection
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13 Notification Version: July 2012 Regulatory Safety Inspections At the start of the inspection, the campus must notify representatives of any campus collective bargaining unit about the inspection
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14 Private questioning Version: July 2012 Regulatory Safety Inspections Inspectors have statutory authority to “question privately any employee or employer” Confidentiality vs. privacy Confidentiality provides protection only of identity of complainant Does not provide anonymity to employees questioned during inspection
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Version: July 2012Regulatory Safety Inspections
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16 Other rules Version: July 2012 Reporting and recordkeeping Injury and illness reporting; exposure and monitoring records; observation of monitoring Employee notification of exposure “Whistleblower” protection For filing complaint For testifying For reasonably refusing to perform a task which represents a danger of serious injury or death Regulatory Safety Inspections
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Posting requirements Version: July 2012Regulatory Safety Inspections 17
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18 The inspection Version: July 2012 Regulatory Safety Inspections
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19 Steps to take now Version: July 2012 Select 3 or more campus management representatives for inspection visits Provide training and awareness of the process Regulatory Safety Inspections
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20 Previous enforcement activity Version: July 2012 Repeated areas of emphasis Personal protective equipment (PPE) Respiratory protection Air contaminants Hazard communication Laboratory Standard Asbestos management Regulatory Safety Inspections
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Previous enforcement activity o Welding o Fume hoods o Chemical storage o Housekeeping o Confined spaces o Signage o Hearing conservation o Bloodborne pathogens o Eyewashes o Emergency response plans Other areas of citation Version: July 2012Regulatory Safety Inspections 21
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22 Team communication Version: July 2012 Set up procedures for how to handle an enforcement action Who in campus management needs to hear about it What information gets shared How to share information Who is responsible for following the action through to the end Regulatory Safety Inspections
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23 Arrival of inspector Version: July 2012 Be polite, cordial, fair and firm Campus management representative should verify the inspector’s credentials/ID State of Wisconsin ID card DSPS on front, Safety & Buildings on back Deputy ID card White with Dept logo and words “Deputy Identification” Back of card has statutory citations Regulatory Safety Inspections
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24 Opening conference Version: July 2012 Regulatory Safety Inspections Ask for a brief opening conference Reason for visit / intended scope If complaint, ask for details of complaint Notify campus bargaining unit reps of inspection Determine the public employee rep on the inspection Know your rights That the inspection is reasonable To be present for the inspection
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25 Opening conference Version: July 2012 Plan/propose inspection route “Go-Kit” Regulatory Safety Inspections
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26 Where is that…? Version: July 2012 OSHA 300 logs Chemical hygiene plan Fume hood test records HazCom program, MSDS records Respiratory protection program Hazard assessments for PPE use Regulatory Safety Inspections
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27 Walking around Version: July 2012 Use of camera If inspector takes a picture, you take same picture Notes Find the right people Be a boring minimalist Admission of violation? Immediate corrections Regulatory Safety Inspections
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28 Wrapping it up Version: July 2012 Closing conference What did inspector determine? What needs to be done? Regulatory Safety Inspections
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29 Post-inspection Version: July 2012 Regulatory Safety Inspections
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30 After the inspector departs Version: July 2012 Regulatory Safety Inspections Office of Safety and Loss Prevention University of Wisconsin System Administration Daniel Karamanski, Occupational Safety Manager (608) 262-4792 dkaramanski@uwsa.edu Inform others involved in safety and management about inspection Inform UW System Formalize your notes
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31 What happens next? Version: July 2012 Workplace in compliance, or… Issuance of orders Comply with orders Appeal: ‘Review by department’ Meetings, review of compliance plans, further inspection visits Regulatory Safety Inspections
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32 If you have questions… Version: July 2012 Contact the Office of Safety and Loss Prevention University of Wisconsin System Administration Daniel Karamanski, Occupational Safety Manager (608) 262-4792 dkaramanski@uwsa.edu Again, links to material related to this topic can be obtained at: http://www.uwsa.edu/oslp/safety/uwsres/Commerce/Commerce_safety_reg.htm Regulatory Safety Inspections
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