OSHA Inspection Procedures

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This will provide a summary of the O.S.H.A. inspection process and the procedures that should be followed by all personnel during an inspection.

I- UPON INSPECTION:

            - Notify management of the inspection

           

            - Ask compliance officer to wait until a management representative is present

             [If this request is denied, the employee representative should accompany the

             Compliance officer.]

            - Ask to see identification from compliance officer

            - Ask what the purpose of the inspection is

            - If you have an active safety program in place, ask to be considered for a Focused Inspection

II- DO’S AND DONT’S:

Act as a professional and do not argue with the Compliance office.  Do not answer any unasked questions or volunteer information.

A- DO:

            - Accompany the inspector at all times.

            - Take photographs of EVERYTHING the compliance officer photographs.

            - Immediately correct ANY items noted as possible violations/citations

- Take detailed notes of the inspection:

                        * Who was interviewed

                        * Items noted as violations

                        * Comments made by compliance officer and others

            - Act as a professional at all times

            - Answer all questions truthfully (Not doing so is a federal offense.)

            - Have an employee to tour with you to correct items as needed

DON’T:

            - DON'T Allow the CO to walk on site unescorted

            - DON'T Argue with the Compliance Officer

            - DON'T Become angry

            - DON'T Admit that something is a violation

            - DON'T Give them documents that were not requested

            - DON'T Lie or mislead the CO.

            - DON'T Answer question based on your OPINION. (i.e.:  Do you think this is unsafe?)

            - DON'T Volunteer information

- DON'T Discuss your knowledge of a violation situation.  You may convince the CO that it is a Willful violation.

III- FORMAT OF INSPECTION:

1- Opening Conference:  The compliance officer will state the purpose of the inspection.  Questions the management representative should ask:

                        - To see credentials of the compliance officer

                        - The purpose of inspection

                        - The SPECIFIC areas the officer plans to inspect.

2- Walking inspection: The compliance officer will walk and inspect the areas that are identified at the opening conference.  The management representative should accompany the officer during this process.

3- Closing conference:  The compliance officer will report the items that were noted and may be subject to a citation.  Make sure you identified all citations that were corrected immediately.  The rights of the employer involved will also be discussed at this point.  The management representative can ask how the alleged violations will be classified.  (i.e.: Willful, Serious, Other than Serious.)

V- EMPLOYERS RIGHTS DURING AN INSPECTION:

1- Rights of the EMPLOYER:

Before the Inspection:

            - To see the inspectors Identification.

            - To have an opening conference.

            - To know the purpose of the inspection.

            - To receive a copy of the complaint causing the inspection.

            - To require an inspection warrant to conduct the inspection.  (This may not be advisable)

            - Time to consult your attorney if you should allow the inspection without a warrant. 

(Reasonable amount of time @ 1 hour.)

           

During the Inspection:          

            - To accompany the inspector during the inspection.

            - To demand the inspection be done in a reasonable manner with respect to time and manner.

            - To require the inspector to follow existing safety policies.

            - To decline to answer the inspectors questions.  (This may not be advisable)

            - To require that employees be interviewed at a time and place that will not interfere with their work.

           

After the Inspection:

- To take a reasonable amount of time to turn requested documents to the compliance officer. 

            - To ask the compliance officer at the closing conference to classify the possible violations as "willful, serious, other than serious."

The Compliance Officer should discuss your rights with you at the closing conference and leave you with a small red pamphlet that will list these items. 

It is your responsibility to exercise our rights!  

POSSIBLE AREAS OF FOCUS DURING AND INSPECTION

**This list does not cover all possible items, but is a good starting point

Correct State of Illinois posters – Illinois right to know

Life safety code issues – Marked exits, blocked exits, emergency lighting (If employees are there after dark) clear isle ways

Fire protection – Proper extinguishers, enough for the SQ FT of building, Travel Distances (Standard - shoot for 1/3000 sqft, no more than 50’ of travel distance) mark extinguisher locations, distances are closer when flammable/combustible liquids are present (25’)

MSDS – Material Safety Data Sheets – Must be available for everything; employees must be able to know where they are and must have free access to them.

Flammable/Combustible storage – Amounts (Large amounts may need to be sprinklered),  Storage cabinets, Proper containers – Gas, kerosene, diesel steel safety cans with spark arrestor and self closing lid, Bulk tanks double walled or diked (catch basin) for spills/leaks

Flammable/combustible liquid transfer – Use a bonding wire to transfer liquids from one container to another

Electrical – No exposed/damaged outlets, no damaged extension cords – missing ground pins, excessive repairs (3 per 25’), exposed copper,  No cords used as permanent wiring, cover all breaker panels (Refer to NFPA 71E)

Tools and equipment – Look for damage, missing guards, missing ground pins, know what items are double insulated vs. in need of a ground pin, damaged cords, ground pins, exposed copper

GFCI – Ground Fault Circuit Interrupters – Electrical protection Detects amperage drop and cuts power at 5mA bleed-off

Safety Training – Provided for employees for everything / on a regular basis, must have documentation (training outline & sign in sheet for employees)

Bottled gas storage – secured, caped, 25’ between oxy & acet. or firewall separator, can be mounted on a torch cart

PPE (Personal Protective Equipment)– Safety glasses, face shields, aprons, welding stuff – coat, gloves, head protection, proper clothing and shoes

First aid – Must have available

Eye wash – Small portable bottles are available

Exposed insulation – Cover any combustible insulation with a fire barrier

Housekeeping – clean work areas free of debris, floors and benches, storage rooms

Dirty rag storage – Greasy and oily rags need to be stored in a fire proof container with a lid

Record Keeping/Documentation – document all trainings, accidents

OSHA 200 & 201 log – Used thru 2002, 200 was internal documentation, 201 was for posting – must post even if there were no injuries

OSHA 300 & 300A log – New for 2003, updated in 2004, watch dates for posting the 300A

HAZ COM – Hazard communication training for employees working with chemicals, clearly mark all bottles/containers, and get rid of all 2-4-d weed killers

General Storage – Eliminate anything that looks unsafe or dangerous

Ladders – No damaged, modified, repaired, or painted ladders, all ladders must have safety feet

Battery charging area – eye wash, fire ext (Proper rating), PPE, no flammable/combustible material, proper battery acid storage (Refer to MSDS)

This information is provided by: Assurance Agency

 

Floor and Wall Openings - On the Job Tool Box Talks

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Overview

OSHA has very specific rules on guarding floor and wall openings and holes, to protect employees from falling and injuring themselves, and to prevent accidental drops of tools or equipment to injure workers below.

Types of openings

OSHA addresses the following types of openings and holes:

Floor holes are openings less than 12 inches but more than 1 inch in its least dimension, in any floor, platform, pavement or yard, through which materials but not persons may fall.

Floor openings are openings which measure 12 inches or more in its least dimension, in any floor, platform, pavement, or yard, through which persons may fall.

Platforms are working spaces for persons which are elevated 4 feet or more above the surrounding floor or ground.  

 Loading docks are platforms.

Wall holes are openings less than 30 inches but more than 1 inch high, or unrestricted width, in any wall or partition.

Wall openings are at least 30 inches high and 18 inches wide, in any wall or partition, through which persons may fall.

Standard railings for floor openings must consist of a top rail, midrail, and posts having a vertical height of 42 inches from the upper surface of the platform, runway, or ramp. Mid rail height is 21 inches.

A standard toeboard is 4 inches nominal in vertical height, with not more than 1/4 inch clearance above the floor level.

Open-sided floors, platforms, loading docks, and runways more than 4 feet above floor or ground level are to be protected on open sides by a standard railing.  

  

This informatio          This information povided by: Assurance Agency

Construction Equipment Dangers-on the job tool box talks

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Construction Equipment used on construction jobs often creates dangerous conditions. This week's Tail Gate Safety Topic examines a few situations which should be watched for at all times.

Any moving equipment such as skip loaders, back hoes, trenchers, cranes, hi-lifts, trucks, you name it, should be respected and avoided. Don't just assume that the operator sees you. You could wind up injured or worse. And don't depend on hearing a horn or an alarm to warn you that moving equipment is near. You may not be able to hear the equipment's alarm over other construction noise.

When you see that equipment is traveling backwards keep out of the way and stand clear until the operator has completed his maneuver. Never cut across the path behind any unit while it is backing. You could easily trip and full under the equipment. For the same reason you should never ride on the running boards, steps or drawbar or any equipment, even for a short distance.

During backing, the operator should have the project foreman clear the area behind the unit and provide direction. No operator should back a piece of equipment into and area without someone clearing the area and giving signals.

Watch out for swinging counterweights on equipment such as cranes. There is often a pinch-point between the counterweights and some obstruction when the unit swings. Make sure there is enough room for workers to pass and if there is not - shut off the area to any access.

Never ride on or near material that is being transported by equipment. The load could shift and you can be thrown to the ground. Also, clearance may not allow for your position and you can be crushed between overhead or side obstructions.

If you must ride on equipment, make sure that all parts of your body are inside the unit, including your arms and legs. In addition, it at all possible, get off any portable scaffold or work platform while the unit is being moved. The time it takes to get off will be much less than the time lost if you fall or the unit tips over.

Never walk alongside moving equipment. Keep in the clear in case it slides or turns, or the load shifts.

When you are working near equipment operating in the vicinity of power lines, don't touch or come in contact with the frame of the unit or the load cables. There is always the chance that the boom of the unit may hit the power lines. Warn the operator and the foreman any time you see this possibility and follow their instructions.

Don't walk under loads on cranes and hoists. Always take the path that avoids danger.

Never clean, adjust, lubricate, repair or work on a machine that is in operation. Stop the machine before working on it and replace the guards as soon as it is done and before operation is resumed.

The safest this to do around construction equipment is keep away while the equipment is in operation. If you must be near the equipment, make sure the operator knows you are working nearby and stay alert. Keeping your mind on where you are in relation to the equipment will not only prevent injuries but could save your life. 

This information is provided by: Assurance Agency

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Safety on a New Jobsite-on the job tool box talks

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It's important for you to remember that most accidents are caused by carelessness or thoughtlessness--yours, or someone else on the job.  When an accident occurs, it is because someone has failed to foresee that it could happen.  If you think ahead of the possible hazards likely to confront you, you can plan how to avoid them. When starting work at a new job site, size up the situation and think of ways to prevent accidents and keep the job safe.

Take time to evaluate your share of the work as soon as you arrive on the site. Ask your supervisor to explain any phase of the job that you do not understand.  If you are working with a new employee, be sure to explain the work to be done and be sure that he/she is qualified to do the work. This will allow you to work safely with this person and prevent accidents.

Always check that you have the necessary tools and equipment required to do the job. Use tools only for the purpose they were designed for. Repair and replace immediately any defective tools such as chisels with mushroomed heads, wrenches with sprung or spread jaws, hammers with split handles, etc. Inspect the wiring of all electrical hand tools to be sure they are equipped with a three-prong grounded plug. Power tools with frayed or broken insulation on wires should be taken out of service until repaired. When using ladders, make sure that they are in good shape with no broken or missing rungs. Never use aluminum ladders when working around electricity. Wear hard hats and other personal protective equipment when called for on the site. When using scaffolding, make sure that it is properly set up with scaffold grade planks and good, stable footing. Do not work on scaffolding that is shaky or missing components.

Remember, a job is only as safe as each person makes it. If each employee will take nothing for granted, check all tools and equipment for safe operation, keep the job neat and follow company rules, they will be contributing to the safety of themselves and their fellow workers.

SIZE UP THE SITUATION - PLAN AHEAD - WORK SAFELY!!!

This information is provided by: Assurance Agency

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