1. Cal/OSHA Consultation Service On-Site Visits
Peter Scholz, MPH, CIH
Assoc. Safety Engineer
Oakland Area Office

2. Cal/OSHA Consultation vs. Enforcement
Confidential (very limited exceptions)
No fines or citations
No cost
Agreeing to fix any hazards found – that is not voluntary.

3. Example: Solar Panel Installation
Fall Protection needed over 7.5 ft.
Ladders must be secured during use
No carrying material up ladders
Need Injury and Illness Prevention Program
Need Heat Stress Program
Fork lift operators need to be formally evaluated

4. Example: Soup Kitchen Train employees on disabling freezer lock
Splash goggles for handling cleaning liquids
Packaging machines – finger entrapment hazards
Hobart mixer unguarded
Eyewash needed
Secure furniture against tipping
Need IIPP, and Hazard Communication Programs

5. Example: Spice Packaging
Blocked access to electrical panels
Openings in electrical panels
Lock-out/ tag-out procedures
Review and implement IIPP
Voluntary respirator use without training
Secure furniture
Blocked fire extinguishers
Complete Log 300s

6. Example.... Exit door needs panic hardware
Liquid nitrogen tank in shipping is unsecured
Ventilation in shipping room not tested annually
Repair oxygen sensor
Improve IIPP
Recommendation: improve ergonomics of lifting sample racks from cryogenic storage tank.

7. Elements of an On-site Consultation
Preparation
Opening conference
Review Safety Record – Log 300, etc.
Program Review
Walk Around
Closing Conference
Report
Hazard Correction

8. Review Safety Record Review Log 300s Reportable injuries Near misses
Documentation ?
Duplicate injuries?
What changed as result?
Programs implemented?
On-going major concerns/ safety focus ?

9. Injury & Illness Prevention Program (IIPP)
A primary focus of Cal/OSHA
Required only in CA
Overall in-house safety program
Includes the required elements (§3203)
Tailored to the company’s safety needs
Implemented and documented

10. IIPP Elements (§3203) Responsibility Employee Compliance
Safety Communication
Workplace Inspection
Injury and Illness Investigation
Hazard Correction
Training and Instruction

11. IIPP Tailored to your needs Short and to the point
Reviewed & Modified (coffee stains are a plus)
Do what you say; say what you do …
Concise documentation

12. Quality Safety Meetings
Required only for construction work
Should be common in all businesses
Good way to meet IIPP safety communication requirement
Often a missed opportunity to make a real difference

13. Quality Safety Meetings
In language that can be understood
Relevant to what’s happening or going to
Involves employee participation
Demonstration, show and tell
Management follow through
Rotate responsibility for leading and presenting

14. What level are you at ? “911” Safety Program
“Big Binder” Safety Program
“Doing it for OSHA” Safety Program
“Safety Nag” Program
“Safety Culture” Program

15. Safety Culture Shared high expectations Shared sense of responsibility
Mutual accountability
Shared drive to improve
Shared ownership

16. Quality Safety Meetings as building Safety Culture
In language that can be understood
Relevant to what’s happening or going to
Involves employee participation
Demonstration, show and tell
Management follow through
Rotate responsibility for leading and presenting

17. Other Written Safety Programs ?
Chemical Hazard Communication
Emergency Medical Services (Construction)
Heat Stress (Outdoor work)
Bloodborne Pathogen Exposure Control
Permit-Required Confined Space
Respiratory Protection
Lock-out / Tag-out Procedures
Aerosol Transmissible Diseases

18. Why Written Programs? A. The more safety binders, the better
B. The bigger the safety binders, the better
C. I really don’t have enough to do
D. It intimidates everyone else
E. Cal/OSHA just loves this stuff
F. All of the above

19. Why Written Programs? Written programs should ensure that:
All aspects have been thought through;
Document actions are fully responsive to regulation
Responsibilities have been assigned;
Maintain institutional memory.
They serve as the basis for employee education
Documentation of implementation is just as important!
Don’t descend into ‘safety binder fetishism’

20. Walk Around Inspection
Machine guarding
Fall hazards
Secure furniture, racks, equipment
Electrical hazards
Eyewash installation and flushing
Personal protective equipment
Compressed gas cylinders
Fire extinguishers

21. Walk Around Inspection
Forklift operators
Obstructed emergency exits
Audit exhaust ventilation annually
Dust conveying ducts – clean-out ports
Chemical hazards not assessed
Noise hazards not assessed
First aid trained personnel

22. Resources http://www.dir.ca.gov/dosh/PubOrder.asp
Or google: Cal/OSHA publications