Addressing 5 key targets of OSHA inspectors
By Jim Stanley
President, FDRsafety
David Michaels is staying on as Assistant Secretary of Labor for OSHA, which in all likelihood means a continuation of OSHA's emphasis on enforcement.
With that in mind, employers would be well-advised to make sure they are addressing five areas where OSHA inspectors frequently find violations. A straightforward way to assess your company's performance is a mock OSHA audit conducted by a safety and/or health professional.
Here is some of the low-hanging fruit for OSHA compliance officers:
* Permit-required confined spaces (29CFR 1910.146)
Employers are required to implement practices and procedures to protect employees in general industry from the hazards of entry into permit-required confined spaces. (The general industry standard does not apply to agriculture, construction or shipyard employment.)
* Control of hazardous energy (lockout/tagout) (29CFR 1910.147)
OSHA regulations cover the servicing and maintenance of machines and equipment in which the unexpected energization or startup of the machines or equipment, or release of stored energy, could cause injury to employees. Employers are required to establish minimum performance requirements for the control of such hazardous energy. (The general industry standard does not cover construction, agriculture and maritime employment. It also does not cover installations under the exclusive control of electric utilities for the purpose of power generation, transmission and distribution; exposure to electrical hazards from work on, near or with conductors or equipment in electric utilization installations; or oil and gas well drilling and servicing.)
* The general requirements for personal protective equipment (29CFR 1910.132)
Identifying hazards that require personal protective equipment for workers and then making sure every worker has been provided the equipment and trained in its use and that they wear it.
* OSHA recording and reporting occupational injuries and illnesses (29CFR 1904)
Employers are required to carefully follow OSHA's regulations that mandate they record and report work-related fatalities, injuries and illnesses.
* Powered industrial trucks (29CFR 1910.178)
Employers are required to follow the safety requirements related to fire protection, design, maintenance and use of fork trucks, tractors, platform lift trucks, motorized hand trucks and other specialized industrial trucks powered by electric motors or internal combustion engines. (This general industry standard does not apply to compressed air or non-flammable compressed gas-operated industrial trucks nor to farm vehicles or vehicles intended primarily for earth moving or over-the-road hauling.)
If and when hazards are identified in the workplace, employers need to develop a plan of action that addresses them. The best overall approach to surviving an OSHA inspection is to have a safe and healthful workplace with a safety and health program to which top management is committed. This program must also involve the employees and hold managers and workers accountable for following safe work practices.
Safety awareness training, which motivates workers to want to
follow safety rules rather than feeling that it is just one more thing they have to do, can also be of great help.
To help make OSHA compliance easier, FDRsafety is offering two documents that address PPE hazard assessments and how to prepare for an OSHA inspection. To obtain these documents, simply email us at info@fdrsafety.com.
Jim Stanley is a former Deputy Assistant Secretary of Labor for OSHA. Contact him at jstanley@fdrsafety.com or (513) 317-5644.
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