I was hoping that in the couple of weeks since the last blog, that the weather would have cooled off, and heat stress would no longer be a relevant topic. That did not occur, and I didn’t seriously expect it to. We will, then, take a closer look at some of the specific ways that heat can affect employees on the job. Heat effects can range from fairly minor to life-threatening, and prevention of all of them is preferable to treating them. Recognizing that hazards exist in the workplace is the first step, and understanding a little more about the more dangerous conditions will help to identify the hazards.
The effect most of us are the most familiar with is probably sunburn. Sunburn is mainly caused by ultraviolet radiation which is most intense between 10:00 AM and 4:00 PM. Workers who must be exposed to the sun during these hours should be encouraged to wear loose-fitting, but long-sleeved shirts and long pants to minimize the amount of bare skin exposed. Wide-brimmed hats will help reduce exposure to the face and ears. Topical sunscreens may also be used, although OSHA does not require the employer to furnish them {29 CFR 1910.132(h)(4)(iii)}. Most sunburns are fairly minor in nature, and may be treated with topical anesthetics, but more severe examples are possible, with blistering, and the subsequent risk of infection possible. Ultraviolet radiation is also strongly linked with chronic conditions such as skin cancer, cataracts, and macular degeneration, so do not ignore the hazards.
Heat exhaustion occurs when the body’s cooling mechanisms begin to fail to cope with heat being generated and heat being absorbed. It can develop over a period of several days of working in hot environments without sufficient hydration, electrolyte replenishment, and rest. In high heat, it can also develop more rapidly. Symptoms of heart exhaustion include fatigue, heavy sweating, muscle cramps, dizziness, and fainting. Treatment should include moving an affected employee to a cool environment, giving cool beverages (no alcohol, and preferably no caffeine) and encouraging effective rest cycles. If heat exhaustion is not treated, it can become more severe and lead to heat stroke, so take the warning signs seriously.
Heat stroke occurs when cooling mechanisms break down, and fail to regulate body temperature. The body’s core temperature begins to rise, and in extreme cases, may reach 106 degrees within ten to fifteen minutes. Heat stroke is life-threatening, and should be treated as a medical emergency (as in, call 911!) Death or permanent disability is possible. Symptoms of heat stroke may include hot, dry skin, with no sweating, severe headache, dizziness, and unconsciousness. While emergency responders are being summoned, try to cool the victim as quickly as possible. Spraying with water, immersing in a pool, or sponging water over the victim will all help. Do not try to give liquids to a victim of heat stroke.
Heat-related disorders can be prevented in the workplace through the use of hazard recognition followed by effective employee training. Of course, follow-up is important to ensure that policies and procedures are being followed, and that they effectively control the hazard. Working in the heat is a requirement for many workers, but it can be done efficiently, and without undue risk, if handled responsibly.
-Jason
Monday, July 25, 2011
Monday, July 11, 2011
Heat Stress Prevention
With the forecast calling for another in a long line of over-100 degree days, and while listening to my air conditioner warm up for its daily struggle, I thought I would share a few thoughts on heat stress.
Heat stress, of varying severity, occurs when the body becomes unable to effectively maintain its temperature, approximately 98.6 degrees Fahrenheit. Every person will react differently to working in the heat, and a wide variety of causal factors can come into play. A person’s age, general health, nutrition, and degree of acclimatization will make a difference, as will medications, smoking, and alcohol use. It is important to train employees to recognize the signs, symptoms, and treatment of heat-related disorders, so they will be better equipped to recognize them in themselves and co-workers.
The body will react to heat by dilating blood vessels in order to move more blood to the skin, carrying heat away from the body. You cannot move cold in; you can only take heat away. Sweating is a mechanism that is also triggered in order to take advantage of the evaporation process in carrying away heat. If this process works correctly, the body temperature will remain stable. If the process cannot keep up with the amount of heat being generated or absorbed, the body will experience heat stress.
The best way to manage heat stress is through prevention, and one of the best methods is to ensure proper hydration. Maintaining the fluid level in the body is crucial to the process of heat removal. If there is not enough blood to move heat to the skin surface, then the mechanism will break down, so maintaining fluid levels is critical. Thirst should not be relied upon in hot weather to judge water needs. Instead, employees should drink water regularly throughout the workday, every ten to twenty minutes. OSHA standards require that employers provide an adequate supply of drinking water in the workplace. If portable containers are used, then they must be clearly labeled, with a tight-fitting lid, equipped with a spigot, and used for no other purpose. In other words, employees may not keep their lunches, soft-drinks, whatever, inside the water container. OSHA also prohibits shared or common drinking cups. If disposable cups are used, then there must be a place to throw them away near the water cooler.
Sports drinks (that have copyrighted names I won’t use here) may also be provided to employees, but the standard only requires water. In all cases, employees should be discouraged from drinking excessive quantities of caffeinated beverages. Soft drinks, coffee, tea, and energy drinks are diuretics, and may actually contribute to dehydration. Excessive alcohol use off-duty (and, on-duty, too, I suppose!) will also make it difficult for employees to stay hydrated on the job. If the body starts out depleted at the beginning of the day, then it is already struggling against a deficit, and will have a much harder time maintaining fluid levels.
As employees work in hot conditions, they will begin to acclimatize, and their bodies will become more efficient at maintaining their core temperatures. Encouraging proper rest breaks, good hydration, and effective recovery off-duty will help to ensure that heat-related illnesses will be kept to a minimum. If you are not sure about your exposure, or the best prevention methods available to you, numerous resources exist to get the answers you need. The OSHA website has good information, and you can always contact a specialist in your area. Next time, we will look at the various forms of heat stress, and their treatment.
Jason
Heat stress, of varying severity, occurs when the body becomes unable to effectively maintain its temperature, approximately 98.6 degrees Fahrenheit. Every person will react differently to working in the heat, and a wide variety of causal factors can come into play. A person’s age, general health, nutrition, and degree of acclimatization will make a difference, as will medications, smoking, and alcohol use. It is important to train employees to recognize the signs, symptoms, and treatment of heat-related disorders, so they will be better equipped to recognize them in themselves and co-workers.
The body will react to heat by dilating blood vessels in order to move more blood to the skin, carrying heat away from the body. You cannot move cold in; you can only take heat away. Sweating is a mechanism that is also triggered in order to take advantage of the evaporation process in carrying away heat. If this process works correctly, the body temperature will remain stable. If the process cannot keep up with the amount of heat being generated or absorbed, the body will experience heat stress.
The best way to manage heat stress is through prevention, and one of the best methods is to ensure proper hydration. Maintaining the fluid level in the body is crucial to the process of heat removal. If there is not enough blood to move heat to the skin surface, then the mechanism will break down, so maintaining fluid levels is critical. Thirst should not be relied upon in hot weather to judge water needs. Instead, employees should drink water regularly throughout the workday, every ten to twenty minutes. OSHA standards require that employers provide an adequate supply of drinking water in the workplace. If portable containers are used, then they must be clearly labeled, with a tight-fitting lid, equipped with a spigot, and used for no other purpose. In other words, employees may not keep their lunches, soft-drinks, whatever, inside the water container. OSHA also prohibits shared or common drinking cups. If disposable cups are used, then there must be a place to throw them away near the water cooler.
Sports drinks (that have copyrighted names I won’t use here) may also be provided to employees, but the standard only requires water. In all cases, employees should be discouraged from drinking excessive quantities of caffeinated beverages. Soft drinks, coffee, tea, and energy drinks are diuretics, and may actually contribute to dehydration. Excessive alcohol use off-duty (and, on-duty, too, I suppose!) will also make it difficult for employees to stay hydrated on the job. If the body starts out depleted at the beginning of the day, then it is already struggling against a deficit, and will have a much harder time maintaining fluid levels.
As employees work in hot conditions, they will begin to acclimatize, and their bodies will become more efficient at maintaining their core temperatures. Encouraging proper rest breaks, good hydration, and effective recovery off-duty will help to ensure that heat-related illnesses will be kept to a minimum. If you are not sure about your exposure, or the best prevention methods available to you, numerous resources exist to get the answers you need. The OSHA website has good information, and you can always contact a specialist in your area. Next time, we will look at the various forms of heat stress, and their treatment.
Jason
Tuesday, July 5, 2011
Permit-Required Confined Space Personnel
Last time, we took a look at confined spaces, and I wanted to explore it a little further in this post.
Once the employer has determined that a space meets all the requirements in the OSHA standard for Permit-Required Confined Spaces, a few roles have to be filled if employees intend to enter the space. The Permit itself will also contain the names of the relevant employees. Training must be provided to designated employees prior to the entry.
The first designated employee will be the Entrant. Entrants are the employees that will perform whatever task is required in the confined space. The authorized entrants are the only employees that may enter the confined space during normal (non-rescue) operations. They should be aware of the relevant hazards to the confined space, as well as the task they intend to perform. They must also stay in contact with the Attendant while they perform their tasks in the confined space. Communication methods will vary, depending on the exact nature of the space, but the main requirement is that the attendant must be able to effectively communicate emergency information back and forth with the entrants.
Next on the list is the Attendant. The attendant is an employee stationed outside a permit-required confined space to convey information to and from the entrants. The attendant must also be aware of the exact nature of the hazards that may be present in the confined space. The attendant may not perform any task that interferes with his primary role as the attendant, but may perform ancillary tasks such as air-monitoring or passing tools back and forth to the entrants. The attendant has the main authority to evacuate the confined space if a threat is detected, so, again, effective communication is paramount. The attendant will also be in the best position to summon emergency help if it becomes necessary. The attendant must not enter the confined space for any reason, and may not leave the space unless properly relieved by another attendant.
The last role that must be designated by the employer is that of the Entry Supervisor. The entry supervisor is the person responsible for coordinating the entry. This is the employee that will make sure that the permit is properly filled-out, that attendant and entrants are designated, and assume responsibility for ensuring that procedures related to the entry are followed. The entry supervisor’s duties are mostly administrative in nature, and this employee may not be physically on the jobsite where the entry occurs. The attendant and the entry supervisor might even be designated as the same person. The entry supervisor, like the attendant may not enter the confined space, although either may perform non-entry rescue.
Through effective hazard recognition and reduction techniques, entry into permit-required confined spaces may be made safely and efficiently. Training and detailed programs and procedures are also required both for regulatory compliance, and employee safety. Employers who demonstrate dedication to these practices benefit from reduced injuries and related costs.
-Jason
Once the employer has determined that a space meets all the requirements in the OSHA standard for Permit-Required Confined Spaces, a few roles have to be filled if employees intend to enter the space. The Permit itself will also contain the names of the relevant employees. Training must be provided to designated employees prior to the entry.
The first designated employee will be the Entrant. Entrants are the employees that will perform whatever task is required in the confined space. The authorized entrants are the only employees that may enter the confined space during normal (non-rescue) operations. They should be aware of the relevant hazards to the confined space, as well as the task they intend to perform. They must also stay in contact with the Attendant while they perform their tasks in the confined space. Communication methods will vary, depending on the exact nature of the space, but the main requirement is that the attendant must be able to effectively communicate emergency information back and forth with the entrants.
Next on the list is the Attendant. The attendant is an employee stationed outside a permit-required confined space to convey information to and from the entrants. The attendant must also be aware of the exact nature of the hazards that may be present in the confined space. The attendant may not perform any task that interferes with his primary role as the attendant, but may perform ancillary tasks such as air-monitoring or passing tools back and forth to the entrants. The attendant has the main authority to evacuate the confined space if a threat is detected, so, again, effective communication is paramount. The attendant will also be in the best position to summon emergency help if it becomes necessary. The attendant must not enter the confined space for any reason, and may not leave the space unless properly relieved by another attendant.
The last role that must be designated by the employer is that of the Entry Supervisor. The entry supervisor is the person responsible for coordinating the entry. This is the employee that will make sure that the permit is properly filled-out, that attendant and entrants are designated, and assume responsibility for ensuring that procedures related to the entry are followed. The entry supervisor’s duties are mostly administrative in nature, and this employee may not be physically on the jobsite where the entry occurs. The attendant and the entry supervisor might even be designated as the same person. The entry supervisor, like the attendant may not enter the confined space, although either may perform non-entry rescue.
Through effective hazard recognition and reduction techniques, entry into permit-required confined spaces may be made safely and efficiently. Training and detailed programs and procedures are also required both for regulatory compliance, and employee safety. Employers who demonstrate dedication to these practices benefit from reduced injuries and related costs.
-Jason
Monday, May 23, 2011
Confined Space Training
One of the more common training types our company has been asked to perform over the last year or so, has been Confined Space Training. Requests come from very diverse sources; from an oil refinery in the Bahamas, to a slaughterhouse outside of Amarillo, TX. (I’ll leave you to guess which of those I taught personally, and which I didn’t!) The one thing they all have in common, is the fact that they recognized the need for confined space training, and understood that OSHA requires employers to provide relevant training to employees exposed to hazards on the job.
The first part of the process is to determine if employees will be exposed to confined spaces on the job. Even if employees will not actually enter the confined spaces onsite, awareness training regarding the hazards may still be needed. Under OSHA guidelines, a confined space:
“(1) Is large enough and so configured that an employee can bodily enter and perform assigned work; and
(2) Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and
(3) Is not designed for continuous employee occupancy.” - 29 CFR 1910.146(b)
A wide range of spaces may fit this description on a given jobsite, so it is important for each employer to assess the worksite to identify these confined spaces. Then next step is to determine if any of the confined spaces qualify as ‘Permit- Required Confined Spaces.’ Basically, if the confined space contains, or has the potential to contain, some other serious hazard (such as bad air, engulfment hazards, etc.) then it becomes a Permit space. You can consult OSHA’s 1910.146 standard for further guidance, or engage a safety consultant to help audit your particular jobsite and needs.
Either way, once the types of confined spaces have been identified, employers must provide training to employees to make them aware of potential hazards on the jobsite. The training should be relevant to the jobsite, and specific enough to address the controls and procedures that will be used on the jobsite. The type of rescue to be used will also play a key role in the extent of the training, because employers wishing to maintain their own onsite rescue teams must also train those teams in the proper use of additional equipment as well as provide practical exercises annually to retain proficiency.
Confined Spaces can be deadly. About 65% of fatalities in confined spaces occur because of bad air, and of those incidents, almost 100% have no air monitoring equipment or powered ventilation. Approximately 60% of deaths in confined spaces are would-be rescuers who lack the proper training to effectively assist a coworker, and about 29% of fatalities are supervisors. All of these statistics point to one thing: a lack of awareness of the hazards of confined spaces that could be mitigated through proper assessment of the workplace, and effective training of employees. Both easily addressed with the resources available to employers.
Stay tuned, and we will look at Permit-Required Spaces more closely in the future.
-Jason
The first part of the process is to determine if employees will be exposed to confined spaces on the job. Even if employees will not actually enter the confined spaces onsite, awareness training regarding the hazards may still be needed. Under OSHA guidelines, a confined space:
“(1) Is large enough and so configured that an employee can bodily enter and perform assigned work; and
(2) Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and
(3) Is not designed for continuous employee occupancy.” - 29 CFR 1910.146(b)
A wide range of spaces may fit this description on a given jobsite, so it is important for each employer to assess the worksite to identify these confined spaces. Then next step is to determine if any of the confined spaces qualify as ‘Permit- Required Confined Spaces.’ Basically, if the confined space contains, or has the potential to contain, some other serious hazard (such as bad air, engulfment hazards, etc.) then it becomes a Permit space. You can consult OSHA’s 1910.146 standard for further guidance, or engage a safety consultant to help audit your particular jobsite and needs.
Either way, once the types of confined spaces have been identified, employers must provide training to employees to make them aware of potential hazards on the jobsite. The training should be relevant to the jobsite, and specific enough to address the controls and procedures that will be used on the jobsite. The type of rescue to be used will also play a key role in the extent of the training, because employers wishing to maintain their own onsite rescue teams must also train those teams in the proper use of additional equipment as well as provide practical exercises annually to retain proficiency.
Confined Spaces can be deadly. About 65% of fatalities in confined spaces occur because of bad air, and of those incidents, almost 100% have no air monitoring equipment or powered ventilation. Approximately 60% of deaths in confined spaces are would-be rescuers who lack the proper training to effectively assist a coworker, and about 29% of fatalities are supervisors. All of these statistics point to one thing: a lack of awareness of the hazards of confined spaces that could be mitigated through proper assessment of the workplace, and effective training of employees. Both easily addressed with the resources available to employers.
Stay tuned, and we will look at Permit-Required Spaces more closely in the future.
-Jason
Friday, May 6, 2011
Monday, May 2, 2011
Hazard Communication and Chemical Safety
The Hazard Communication Standards, also known as the ‘Right-to Know’ standards are in place to ensure that workers have access to the information they need to safely work with chemicals in the workplace. Prior to implementation of the Hazcom standards, workers in America did not always have complete information about the chemicals around them, and as a result, many got sick, and many died from exposure to hazardous substances on the job. OSHA’s 1910.1200 addresses this issue.
Exposure to chemicals in the workplace can have greatly varied effects, depending on several variables, including relative toxicity, concentration of the chemical, time in contact, and route of entry. Personal factors such as age, general health, nutrition, and previous exposure can all take a role. Effects of chemicals be acute or chronic. In acute exposure, the effects of a chemical are noted immediately after exposure. Consider flooding a room with ammonia gas: people in the room would notice immediately, and begin coughing, experiencing burning in the eyes, and other immediate effects. Chronic effects are long-term effects that are not noted until months or years after the exposure. Amphibole asbestos exposure, for example, would produce no immediate effects in the body, and it would only be after years that the effects would begin to show.
One of the key aspects of the program, then, is that employers must furnish information about potential chemical hazards to employees, and this is done in several important ways. The first one is assessment of the hazards. Employers must audit the workplace in order to note what chemicals are in use, and what types of protections are required for employees. Then, the employer must communicate the hazards and the control methods to employees in training classes held on an annual basis. There are many resources available to help employers evaluate their workplace and determine effective hazard controls; OSHA, chemical manufacturers, chemical labels, trade magazines, safety consultants, and material safety data sheets can all provide valuable insight.
Material safety data sheets (MSDS) are informational documents provided by the chemical manufacturer or importer that describe the chemical’s physical characteristics, fire/explosion data, and health effects, among other things. Employers must catalog an MSDS for all chemicals in the workplace, (with a few exceptions) and make the MSDS’s available to employees at all times. The MSDS book must also be reviewed annually to ensure that it remains current, and that all chemicals in the workplace have a corresponding sheet.
Chemical safety in the workplace is an important part of any overall safety program. The elements of Hazcom are easy to implement, and with proper practices and quality training, incidents involving chemicals can be lessened, and injuries and illnesses can be greatly reduced.
-Jason
Exposure to chemicals in the workplace can have greatly varied effects, depending on several variables, including relative toxicity, concentration of the chemical, time in contact, and route of entry. Personal factors such as age, general health, nutrition, and previous exposure can all take a role. Effects of chemicals be acute or chronic. In acute exposure, the effects of a chemical are noted immediately after exposure. Consider flooding a room with ammonia gas: people in the room would notice immediately, and begin coughing, experiencing burning in the eyes, and other immediate effects. Chronic effects are long-term effects that are not noted until months or years after the exposure. Amphibole asbestos exposure, for example, would produce no immediate effects in the body, and it would only be after years that the effects would begin to show.
One of the key aspects of the program, then, is that employers must furnish information about potential chemical hazards to employees, and this is done in several important ways. The first one is assessment of the hazards. Employers must audit the workplace in order to note what chemicals are in use, and what types of protections are required for employees. Then, the employer must communicate the hazards and the control methods to employees in training classes held on an annual basis. There are many resources available to help employers evaluate their workplace and determine effective hazard controls; OSHA, chemical manufacturers, chemical labels, trade magazines, safety consultants, and material safety data sheets can all provide valuable insight.
Material safety data sheets (MSDS) are informational documents provided by the chemical manufacturer or importer that describe the chemical’s physical characteristics, fire/explosion data, and health effects, among other things. Employers must catalog an MSDS for all chemicals in the workplace, (with a few exceptions) and make the MSDS’s available to employees at all times. The MSDS book must also be reviewed annually to ensure that it remains current, and that all chemicals in the workplace have a corresponding sheet.
Chemical safety in the workplace is an important part of any overall safety program. The elements of Hazcom are easy to implement, and with proper practices and quality training, incidents involving chemicals can be lessened, and injuries and illnesses can be greatly reduced.
-Jason
Monday, March 14, 2011
Managing OSHA Inspections
Employers of every size and type must comply with the regulations of the Occupational Safety and Health Act (OSHA). While some of the provisions of the Act may seem burdensome, worker safety should be the highest priority, so it is in your best interests to comply as fully as possible with all applicable OSHA standards.
No matter how careful you are, there is always a chance that an OSHA official will conduct an inspection of the facility or jobsite. The following steps offer a guideline for what actions you should take when an inspection is made:
1. Review the Compliance Officer’s (CO's) credentials and determine the reason for the inspection, and whether or not you wish to allow it. Calling 1 (800) 321-OSHA will enable you to verify the inspector’s information.
2. Contact Comprehensive Safety Resource toll-free at (855) 215- 2736 to speak to one of our experienced occupational safety consultants regarding your situation.
3. Determine the CO's intended scope for the inspection, including: records to be reviewed, areas to be examined, tests to be conducted, and employees to be interviewed. Resolve any objections you have before continuing the inspection.
4. A manager or experienced company official should accompany the inspector at all times, especially during the walk-around phase of the inspection. It is beneficial to have the safety director or a safety consultant present, as well. Ensure that only the agreed upon areas are examined. Make note of all items reviewed by the inspector and any comments he or she makes.
5. If the CO points out a potential violation, record the precise circumstances of the condition, including the length of time the condition existed, names of exposed employees, potential for injury, and any facts ignored by the CO. When possible, make immediate corrections to the hazards and make note of the corrections, as well as documenting the abated area with a photograph. Always demonstrate a good faith effort to protect employees’ safety and health.
6. If possible, duplicate any photos and/or tests made by the CO. At a minimum, record the procedures and details used by the CO.
7. The Closing Conference will be used to discuss preliminary findings. This is the easiest time to correct misunderstandings.
INSPECTION DO’s
Tell the Truth
1 Promptly provide statutorily required documents/records
2 Take notes on everything the inspector says or examines
3 Take measurements and make drawings, or photograph them (if OSHA does)
4 Keep a record of employee interviews
5 Ask the inspector to explain perceived violations and look up applicable standard
INSPECTION DON’T’S
1 LIE
2 Admit knowledge of violations
3 Tell workers not to talk to OSHA
4 Agree that a violation exists
5 Provide non-statutorily required documents
6 Guess or speculate
WHEN THE CITATIONS ARRIVE
1. Read them carefully. Look for the assigned abatement dates. If you plan to contest, do it now.
2. Post the citations at or near each worksite involved for a minimum of three days or until the citations are abated.
3. Abate all citations within the prescribed period.
4. Address each citation formally in a response letter due to OSHA no later than the last assigned abatement date. Mail it as soon as possible.
5. Get ready for the next inspection. An OSHA follow-up inspection is possible.
APPEALING CITATIONS
Once the inspection is completed, OSHA has six months to issue citations, although they are typically issued much sooner. If citations are made, you will have 15 working days - beginning the day you receive the citations - to file a Notice of Contest appealing the citations. The Notice should be filed with Area Director of your local OSHA office. If there is any possibility that you may contest the citations, you should file the Notice. Failure to file the Notice in a timely fashion may result in losing any right to contest the citations. Contact Comprehensive Safety Resource, L.P. for assistance in appealing your citation. If you decide not to appeal, the Notice can be dropped without penalty prior to the hearing.
-Jason
No matter how careful you are, there is always a chance that an OSHA official will conduct an inspection of the facility or jobsite. The following steps offer a guideline for what actions you should take when an inspection is made:
1. Review the Compliance Officer’s (CO's) credentials and determine the reason for the inspection, and whether or not you wish to allow it. Calling 1 (800) 321-OSHA will enable you to verify the inspector’s information.
2. Contact Comprehensive Safety Resource toll-free at (855) 215- 2736 to speak to one of our experienced occupational safety consultants regarding your situation.
3. Determine the CO's intended scope for the inspection, including: records to be reviewed, areas to be examined, tests to be conducted, and employees to be interviewed. Resolve any objections you have before continuing the inspection.
4. A manager or experienced company official should accompany the inspector at all times, especially during the walk-around phase of the inspection. It is beneficial to have the safety director or a safety consultant present, as well. Ensure that only the agreed upon areas are examined. Make note of all items reviewed by the inspector and any comments he or she makes.
5. If the CO points out a potential violation, record the precise circumstances of the condition, including the length of time the condition existed, names of exposed employees, potential for injury, and any facts ignored by the CO. When possible, make immediate corrections to the hazards and make note of the corrections, as well as documenting the abated area with a photograph. Always demonstrate a good faith effort to protect employees’ safety and health.
6. If possible, duplicate any photos and/or tests made by the CO. At a minimum, record the procedures and details used by the CO.
7. The Closing Conference will be used to discuss preliminary findings. This is the easiest time to correct misunderstandings.
INSPECTION DO’s
Tell the Truth
1 Promptly provide statutorily required documents/records
2 Take notes on everything the inspector says or examines
3 Take measurements and make drawings, or photograph them (if OSHA does)
4 Keep a record of employee interviews
5 Ask the inspector to explain perceived violations and look up applicable standard
INSPECTION DON’T’S
1 LIE
2 Admit knowledge of violations
3 Tell workers not to talk to OSHA
4 Agree that a violation exists
5 Provide non-statutorily required documents
6 Guess or speculate
WHEN THE CITATIONS ARRIVE
1. Read them carefully. Look for the assigned abatement dates. If you plan to contest, do it now.
2. Post the citations at or near each worksite involved for a minimum of three days or until the citations are abated.
3. Abate all citations within the prescribed period.
4. Address each citation formally in a response letter due to OSHA no later than the last assigned abatement date. Mail it as soon as possible.
5. Get ready for the next inspection. An OSHA follow-up inspection is possible.
APPEALING CITATIONS
Once the inspection is completed, OSHA has six months to issue citations, although they are typically issued much sooner. If citations are made, you will have 15 working days - beginning the day you receive the citations - to file a Notice of Contest appealing the citations. The Notice should be filed with Area Director of your local OSHA office. If there is any possibility that you may contest the citations, you should file the Notice. Failure to file the Notice in a timely fashion may result in losing any right to contest the citations. Contact Comprehensive Safety Resource, L.P. for assistance in appealing your citation. If you decide not to appeal, the Notice can be dropped without penalty prior to the hearing.
-Jason
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