Haven’t been inspected by OSHA, or, at least not recently?  Here are the top-10 dos and don’ts during OSHA inspections, according to two actual OSHA inspectors:

1. Don’t make me wait. It just tells me you’re not ready. Nothing you can do at the last minute is going to make much difference anyway.
2. It’s best to be open with me.
3. Don’t try to block my line of sight by bringing a bunch of employees along on the walk-through. I’ll wait until I get to see what I want to see. Some of us use digital cameras. Some of us even videotape the inspection.
4. Be prepared to answer questions. Have all required OSHA documents, including those outlining safety plans, ready for me.
5. Don’t discourage employees from talking to me. I’ll talk to them one way or another. I find ways to slip employees my business card, and once I do, they usually call. If necessary, I’ll get a subpoena to talk to your employees.
6. Don’t lie to me. That makes me angry.
7. Think about hazards, not just standards, when you evaluate your workplace for safety. I look for hazards, not standard violations.
8. Have your training documents in order. I do look at them. If you have Hispanic employees, make sure you have documentation that they understood your safety training.
9. Plan ahead and designate a person or people who will meet with me. Make sure the person is prepared. It doesn’t matter to me whether you have a full-time safety manager or not. That doesn’t make me any tougher or easier on a company.
10. Check out OSHA’s Field Operations Manual for inspectors. Even though it’s written for inspectors, it’s available to anyone for free on the OSHA website (you can download a PDF here). It’s a great resource to prepare any company for the possibility of an OSHA inspection.

OSHA’s Field Operations Manual
http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-00-148.pdf

(Two OSHA inspectors provided these tips at the American Society of Safety Engineers’ 2010 annual conference.)

In the previous post, we discussed how the Congress threw out OSHA’s 2001 “Ergonomics rule” and how, ever since then, OSHA has been looking for a way to get back in the Ergonomics Enforcement business.  (Not that OSHA has ever REALLY been out of the business; citations have been issued under the “General Duty Clause” before and since 2001.)  Under the current administration, there is expected to be a push for another new Ergonomics rule.

In what is viewed by some as “the camel’s nose under the tent“, in January, 2010, OSHA proposed adding a separate column on the OSHA 300 log for employers to record work-related musculoskeletal disorders (MSDs).  The rule also proposes the same definition of “MSDs” that OSHA had included in the initial 2001 final rule, and some say that this new definition is much more comprehensive and much more confusing than the traditional definition. 

OSHA is moving this Rule forward at what is, to a government agency, light speed.  The period for comments was only two months (now closed) and only one public hearing was held.

OSHA describes this proposed rule as a non-significant regulatory action involving only two small costs for employers. OSHA believes that:

1.  Employers - and specifically a human resources specialist - will be required to spend 5 minutes familiarizing themselves with the rule; and  

2.  Employers will need to spend one additional minute than they currently spend in analyzing an injury or illness to determine whether it should be classified as an “MSD” and put into the correct column on the new recordkeeping forms.

This may be true… but, after all, the camel’s nose is rather small and insignificant as well…

OSHA Press Release on the MSD recordkeeping rule:

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=NEWS_RELEASES&p_id=17124

Another more critical opinion on the matter:

http://www.nam.org/~/media/69BEB9300C684D7FA3054CC979D2BABA/Fact_Sheet_on_OSHAs_Proposed_Rulemaking_on_MSDs.pdf

Meanwhile, OSHA is continuing their plan for aggressive enforcement of ergonomic issues through the General Duty Clause, as discussed in this article:

http://ergonomicedge.wordpress.com/2010/04/30/oshas-new-ergonomic-regulation-hidden-in-plain-sight/

Safety is not just a series of unrelated activities… it is a way of doing business, a mindset, a culture… a Safety Culture.

 ”To be successful, safety must be more than a program or a book or a procedure. It must be a company philosophy - an attitude that is unquestioned.”
Les McGraw, Fluor Corporation Chairman and CEO

Over the years, safety professionals have identified a number of characteristics that are coming in companies with a superior safety culture.  Specific behaviors, attitudes, procedures, expectations and systems that are part of a dynamic safety culture environment, both for normal operations and for emergencies, have been identified:   (more…)

Because of their enforcement role, sometimes, we are inclined to regard OSHA as “the enemy”.  It is important to remember, though, that they are also a great source of safety and health resource material and training guides.

 In particular, OSHA’s Salt Lake Technical Center (SLTC) has a wealth of good information.  The entry point to their “Safety and Health Topics Pages” is found here.  Use the pop down in the “Quick Links” box to see the available topics, or use the SEARCH feature.

    http://osha.gov/SLTC/index.html

Also be sure to see the OSHA Publications List, from which you can download OSHA forms and booklets and/or order printed copies of them

    http://osha.gov/pls/publications/pubindex.list

OSHA has published a proposed rule that would revise requirements for the prevention of slips, trips, and falls in general industry workplaces.  OSHA’s “Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems)” proposed rule would affect virtually every general industry workplace in the country.  Slips, trips, and falls have long been one of the leading causes of OSHA recordable injuries and OSHA estimates that its proposed rule will prevent 20 fatalities and eliminate 3,500 serious injuries every year.

The proposed OSHA rule revises OSHA’s Subparts D and I of the general industry standards related to ladders, scaffolds, and fall protection, among other things.  The rules also include a general requirement that employers keep places of employment, passageways, storerooms and service rooms clean and in a sanitary condition, a requirement that has been widely applied by OSHA to a number of workplace hazards, including combustible dust.

Some of the key aspects of the proposal are: (more…)

Summer is upon us, and is it HOT!  With warmer temperatures, employees working outdoors (or in a hot warehouse) should be especially careful of the sun, heat and other hazards brought on by the summer climate.

Who is most at risk?

• Infants, young children, elderly and pets
• Individuals with heart or circulatory problems or other long-term illness
• Employees working in the heat
• Athletes and people who like to exercise (especially beginners)
• Individuals taking certain medications that alter sweat production
• Alcoholics and drug abusers

To reduce the risk of heat stress, OSHA recommends that employees:

• Know symptoms, including headaches, dizziness, lightheadedness or fainting;
• Block out direct sun and other heat sources;
• Use cooling fans/air-conditioning; rest regularly;
• Wear a wide-brim hat, cap or bandana, and sunglasses that block UV rays; and
• Drink plenty of cool water, about a cup every 15 minutes.

It is especially important for you and your employees to know the difference between “heat exhaustion”, which requires prompt treatment, and “heat stroke”, which is a serious, call-911, medical emergency.  Read more about heat stroke and heat exhaustion in the National Safety Council’s “Surviving the Hot Weather” Fact Sheet.

http://www.nsc.org/news_resources/Resources/Documents/Surviving_the_Hot_Weather.pdf

OSHA has made available their printable Heat Stress QuickCard^® (English/Spanish) for employers and employees on preventing injury and illness while working in hot weather.  This is worth printing and distributing to your workers. 

Studies have shown that drivers using cell phones, and especially when trying to text and drive, are as impaired as if they have had several drinks.  Hands-free devices are a start, but not a final solution, because the real impairment comes from the fact that the driver’s MIND is not on the road (and, in the case of texting, neither are his EYES!)

Employers should take a strong role to ensure that mobile workers are using their cell phones safely and not putting their life or that of others at risk due to cell phone usage. Employers can create cell phone safety policies to outline situations and repercussions for those who fail to follow the policies. Polices can be created with input from both management and remote workers to help ensure that there is a fair balance and that the policies are realistically workable and enforceable.  Goals: (more…)

Most of your will recall that, in the final days of the Clinton administration, OSHA enacted a new Ergonomics Standard. This massive standard was quickly repealed by the Congress in 2001. The way the law is written, the repeal of an agency regulation also bars that agency from issuing a similar rule in the future. Because the repealed Standard was so broad and comprehensive, it has been thought that it would be difficult for OSHA to pass a new Ergonomics standard. This hasn’t stopped OSHA’s enforcement on ergonomics, and OSHA recently reported that the agency has issued 19 “General Duty Clause” citations for ergonomics since 2002.

Now, under the Obama administration, OSHA Ergonomics is getting another look… (more…)

There are safety meetings and then there are safety meetings. For instance, you might have a weekly safety meeting on a specific topic, providing new information to your rookies and a review for the experienced workers.

 Another kind of safety meeting is the quick get-together before a specific job when you review the hazards and outline the procedures and emergency measures. These are called tailboard or tailgate meetings, because they often take place around the back of a truck at a construction job site. However, Tailgate Meetings can be used in ANY work environment, from confined space entry to moving furniture in the office, and especially when something new or unusual is to be done. (more…)

During 2008 there was a tremendous focus from OSHA and employers on personal protective equipment: who is required to provide the equipment, who pays for the equipment and who is to maintain and replace. For all that effort, many times it simply boils down to the fact that the equipment is available, but not necessarily always worn.

It’s one of the top challenges safety pros face year after year. In a recent survey, 290 safety professionals were asked about about their experiences to find out the top reasons workers give for not wearing PPE. And we also asked safety managers how they deal with the problem. Here are the results: (more…)

The U.S. Court of Appeals for the Eighth Circuit, in a 2-1 decision, ruled that in the case of Elaine Chao v. Summit Contractors, OSHA regulation 29 C.F.R. Sec. 1910.12(a) “is unambiguous in that it does not preclude OSHA from issuing citations to employers for violations when their own employees are not exposed to any hazards related to the violations.” Therefore, according to the ruling, the Occupational Safety and Health Review Commission (OSHRC) “abused its discretion in determining that the controlling employer citation policy conflicted with the regulation.” (more…)

The truth of the matter is that the average small or medium-sized employer will never see an OSHA Compliance Officer in the life of the business. On the other hand, if you have a serious accident or fatality, or if you are in the news for some safety-related problem, or an employee files a complaint against you, you might see a Compliance Officer tomorrow. Your IWLAIC Safety Manual has a chapter on how you should prepare for an OSHA inspection, and what you should do if you receive a complaint notice by fax from OSHA, or if an OSHA Compliance Officer shows up at your door. It is important to read this section in advance, so you will be ready when the time comes… (more…)

Employers who use forklifts in their workplaces have a new resource to help keep their employees safe on the job. OSHA’s Powered Industrial Trucks (Forklift) eTool…

http://www.osha.gov/dcsp/products/etools/pit/index.html

…is the latest Web-based training tool unveiled by OSHA. This eTool, which identifies forklifts commonly used in general industry, provides a review of potential hazards and a summary of key OSHA requirements and industry-recommended practices for forklift operations. It includes four modules examining the types of forklifts, safe operating practices, workplace conditions affecting operation, and operator training. OSHA offers other eTools on occupational safety and health topics on its eTools web site at:

http://www.osha..gov/dts/osta/oshasoft/index.html

If you are a safety director who has to justify the cost of safety-related activities or expenditures to management, or if you are a manager who wants to understand why you should make those expenditures, the bottom line reason is that it is in your company’s own selfish best interests to do so. 

Many employers tend to think of safety and accidents as things that exists ALONGSIDE their regular business activities, rather than being a PART OF those business activities. Instead, we should “bring it home” by expressing the cost of accidents in terms of our regular business operations. (more…)

The other thing that government agencies pay attention to is stories in the news media, especially stories of major catastrophes that point the finger of blame on the government agency. Last year saw one such major catastrophe involving combustible dust, and so it is no surprise that OSHA has announced that combustible dust will be one of their emphasis points for 2009.

Most often, when safety professionals think of combustible dust explosions, we think of grain dust. Years ago, it was common for grain elevators in the farming regions to explode due to combustible dust. How does this happen? (more…)

The US Navy’s Safety Center maintains an archive of interesting and humorous safety-related pictures. Although safety is a serious matter, we can often make the audience pay better attention if we spice up the presentation with some humor. See the first additions to the 2009 photo archive here, and be sure to click the link for the “Archive 2007/08″ to see last year’s photos.

http://www.safetycenter.navy.mil/photo/archive/default.htm

 

Other interesting information is also linked from their photo archive page. Check it out.

Despite the above fatalities number, the rate of workplace injuries and illnesses in private industry declined in 2006 (the most recent year for which full data is available) for the fourth consecutive year, according to a recent report by the Labor Department’s Bureau of Labor Statistics (BLS).  Full details here:

 

http://www.bls.gov/news.release/pdf/osh.pdf

 

We must be doing something right!