April 11th, 2012
There are four key actions you can take to prepare your organization, make it a safer place, and help to prevent citations in the event of an OSHA inspection:
- Implement an injury and illness prevention program
- Prepare for an OSHA inspection in advance
- Train your managers and employees about safety
- Conduct self-audits and reviews
Injury and Illness Prevention Programs
The DOL has started the P3 Initiative Program—plan, prevent, protect—which would require planning, implementing, evaluating and improving processes and activities. This is similar to conducting your own audits, but would go the further step of being systematic and required.
Additionally, OSHA is considering applying a standard that requires employers to have injury and illness prevention programs, which some states already have. It is currently at the “pre-rule” stage. If implemented, it would build on voluntary safety and health management program guidelines currently in existence.
What happens if you do have an OSHA inspection? How can you be prepared? Casey outlines some preparatory steps you can take:
- Make sure you have the OSHA poster up.
- Assign responsibilities for all aspects of an inspection. The minute an inspector walks in the door, he or she needs to be met by personnel prepared to deal with the situation.
- Training should be in place and documented.
- Ensure required records are complete, current, and available. Designate a person to be responsible for providing requested records.
- Have any equipment needed during the inspection ready to go (for example, cameras to record the inspection).
- Review insurance and third-party audits and take action accordingly.
- Prevent complaint inspections by enlisting employee involvement and ideas. Encourage employees to address safety concerns immediately and internally.
- Conduct hazard assessment and abatement.
- Review of previous citations and ensure that all previous OSHA citations are corrected.
- Establish work rules designed to ensure safe work and to avoid OSHA violations, communicate the work rules to employees, and enforce the rules and practices when violations are discovered.
- Know which OSHA standards are applicable and be compliant with those standards.
- Ensure support staff such as receptionists, secretaries, guards, etc., are trained in how to react and know what to say when the government is at your door.
Managers and employees alike need to be trained and held accountable for implementing training skills and information on the job.
Managers in particular need to be trained to set an example by following the safety rules. They should be able to identify hazards and evaluate employee safety performance.
Employees must have any required OSHA training, and, of course, need to be trained on your worksite rules as well. Don’t just assume employees know the rules. Make sure.
Workers also need to understand how to identify hazards and how to report safety problems. They must understand OSHA protections as well and know that they are not required to work in an unsafe environment.
When the rules and procedures you train on are not followed, there need to be repercussions. Don’t be afraid to discipline when necessary. That sends a firm message that unsafe behavior will not be tolerated.
In addition to a good training program, Casey emphasizes the importance of conducting self-audits and safety reviews on a regular basis. This is the best way to anticipate problems and get them fixed before an OSHA inspector ever gets to your door.
Self-audits will help you identify and correct hazards, update safety programs, and analyze OSHA logs and other records for patterns that will help you identify and correct problem areas.
Casey urges her clients to watch out for these pitfalls when conducting self-audits:
- Infrequent audits. Even if you have a self-audit program in place, it is easy to get complacent and not complete it frequently enough to have real impact.
- Incomplete audits. It is also easy to only complete a partial audit instead of a full audit.
- Not correcting hazards found. Casey notes, “Once you identify a hazard, you now have knowledge of it . . . there’s a piece of paper that OSHA’s going to hold up in court.” So be sure get any problems uncovered in a self-audit are fixed. This shows you’re taking the matter as seriously as you would an external audit or OSHA inspection. If you can’t fix something immediately, steps need to be taken to ensure employee safety until the time it can be fixed (such as taking a machine out of service, for example). Assign responsibility for fixing the problem, and hold those designated accountable for successfully resolving the problem.
- Failure to document. Be sure to document your audits and corrective actions taken. This documentation will help prove good faith compliance with OSHA regulations.
Contact SWMSC today for more information on how our low cost programs can not only save you money, but prevent OSHA from issuing you expensive citations.