What to do to prepare for an OSHA Audit

Meet the SpeakerRick Foote

OSHA Has Been Busy

• OSHA Conducted 92,000 inspections

• There were over 188,000 violations cited

• There was approximately $240 million in penalties

Top 10 Violations1. Hazard Communication

2. Respiratory Protection

3. Electrical ‐ Wiring and Equipment

4. Powered Industrial Trucks

5. Lockout/Tagout

Top 10 Violations6. General Machine Guarding

7. Electrical Systems Design (General)

8. Personal Protective Equipment (General)

9. Fall protection (Guarding Floor/Wall Openings and Holes)

10. Exit routes

Are you ready for OSHA to knock at the door?

OSHA Inspections:Preparation is Key!

Form a Committee• EH&S

• Facilities Dept.

• Maintenance

• Environmental Services

• Clinical Lab

• Researcher Admin.

• Radiology

• Pharmacy

• Plant Operators

Organize Internal Resources

• Preparedness Coordinating Committee

• Facility Program Managers/Experts

• Facility Inspector Escorts

• Logistics and Planning

• Roles & Responsibilities

• Communications

Inspection PreparednessCoordinating Committee• Organizes and facilitates the Opening

Conference

• Works out schedule with the inspectors

• Coordinates inspections with department/program managers

• Conducts daily debriefings

• Organizes and facilitates the Closing Conference

Facility Inspector Escorts•Introduces the inspector and

convey seriousness of the interview.

•Intercedes when leading questions are asked during an interview

•Tactfully restates misunderstood questions to interviewee.

•Doesn’t allow unqualified people to respond to questions

OSHA Inspections - Tips• Be Prepared!

• Maintain up-to-date plans and records

• Know where documents are; be able to produce them in a timely manner

• Have a Preparedness Plan

• Records and Documentation Review• Assemble materials requested by OSHA

• Identify conference room (do not use offices) for records review

• Offer only requested documents for specific locations

• Make duplicate copies of records that they copy

The Inspection

Inspections: Logisticsand Planning

• Internal Notification (“The British are Coming”)

• Enacting the Preparedness Plan

• Opening Conference

• Coordinating a schedule with OSHA

• Debriefings with parties inspected

Opening Conference• State that the group has been assembled to

help facilitate the inspectors’ review & provide an open communication channel with key facility officials

• Outline positive working relationship with OSHA inspectors

• Discuss how important compliance is to your facility

• Who in upper management is involved and how often your department meets with them

• Obtain an understanding of inspection scope

Guidelines: Site Inspection• Identify nature and scope of inspection

• Accompany each inspector at all times

• Cooperate, but do not offer information not requested

• Duplicate all records copied

• Take good notes, photographs, split samples

• Monitor employee interviews

• Conduct an exit interview for each area to get an idea of what they found

Facility Escort Guidelines • Restate unclear answers from the

interviewee to the OSHA inspector.

• Stay by the inspectors side

• Take notes

• During and shortly after the interview

• Of issues that the inspector notes during the inspection

• Of questions that could not be answered

Taking care of business

• Fixing Potential Violations

• As issues are found

• Prior to OSHA entry

• Before OSHA finishes for the day

• Behind the Scenes During the Inspection

• OSHA Location during the day

• Fielding questions

Closing Conference• Consider having VP

level representative and attorney present

• Present documentation of correction actions taken during the inspection

• Have answers to questions that couldn’t be answered in the field

More Guidelines• Take notes

• Don’t attempt to deal with hypothetical situations

• “Fix” simple deficiencies along the way

• Make a copy of anything given to the inspectors

• Seek approval for all photos requested by the inspectors; take duplicate photos

• Likewise, take duplicate samples

Guidelines Continued…•Don’t offer an opinion or agree/disagree with the inspectors

•Do talk about sports, music, general topics

•Don’t be their “buddy” or confidant

•Don’t sign anything

•Keep them from harm’s way (no confined space entry or near high hazard areas)

Guidelines Continued…• Don’t offer information unless specifically

asked

• Don’t argue with the inspectors

• Don’t complain about the regulations

• Don’t be pushed into giving an answer if you don’t know…say that you don’t know

• Don’t be evasive. Answer directly and succinctly

• Don’t lie to the inspectors or misrepresent what really happens in your area

• Don’t engage in speculation

Training Requirements

OSHA Regulations Requiring Training

• 1910.38 - Emergency Action Plans

• 1910.39 - Fire Prevention Plans

• 1910.66 - Powered Platforms for Building Maintenance

• 1910.95 – Occupational Noise Exposure

• 1910.106 – Flammable and Combustible Liquids

• 1910.109 - Explosive and Blasting Agents

• 1910.110 - Storage and Handling of Liquefied Petroleum Gases

• 1910.111 - Storage and Handling of Anhydrous Ammonia

• 1910.119 - Process Safety Management of Highly Hazardous Chemicals

• 1910.120 - Hazardous Waste Operations and Emergency Response

OSHA Regulations Requiring Training

• 1910.124 - General Requirements for Dipping and Coating Operations

• 1910.132 – Personal Protective Equipment

• 1910.134 – Respiratory Protection

• 1910.142 - Temporary Labor Camps

• 1910.145 - Specifications for Accident Prevention Signs and Tags

• 1910.146 – Permit Required Confined Spaces

• 1910.147 – The Control of Hazardous Energy (lockout-tagout)

• 1910.151 - Medical Services and First-Aid

• 1910.155 – 1910.165 – Fire Protection (includes portable fire extinguishers)

OSHA Regulations Requiring Training

• 1910.177 - Servicing of Multi-Piece and Single-Piece Rim Wheels

• 1910.178 – Powered Industrial Trucks (forklift operator training)

• 1910.179 – Overhead and Gantry Cranes

• 1910.180 – Crawler, Locomotives and Truck Cranes

• 1910.181 – Derricks (material handling)

• 1910.183 – Helicopters (for material handling)

• 1910.184 – Slings (material handling)

• 1910.217 – Mechanical Power Presses

• 1910.218 – Forging Machines

• 1910.252 – 1910.255 – Welding, Cutting and Brazing

OSHA Regulations Requiring Training

• 1910.261 - Pulp, Paper, and Paperboard Mills

• 1910.262 – Textiles

• 1910.264 - Laundry Machinery and Operations

• 1910.265 – Sawmills

• 1910.266 – Logging Operations

• 1910.268 – Telecommunications

• 1910.269 - Electric Power Generation, Transmission, and Distribution

• 1910.272 – Grain Handling Facilities

• 1910.332 – 1910.333 – Electrical Safety Related Work Practices

• 1910.410 – 1910.440 - Commercial Diving Operations

OSHA Regulations Requiring Training

• 1910.1000 – Toxic and Hazardous Substances

• 1910.1001 – Asbestos

• 1910.1003 – 1910.1016 – Thirteen Carcinogens

• 1910.1017 – Vinyl Chloride

• 1910.1018 – Inorganic Arsenic

• 1910.1020 - Access to Employee Exposure and Medical Records

• 1910.1025 – Lead

• 1910.1026 - Chromium (VI)

• 1910.1027 – Cadmium

• 1910.1028 – Benzene

• 1910.1029 - Coke Oven Emissions

• 1910.1030 – Bloodborne Pathogens

• 1910.1043 – Cotton Dust

OSHA Regulations Requiring Training

• 1910.1044 - 1,2-Dibromo-3-Chloropropane

• 1910.1045 - Acrylonitrile (Vinyl Cyanide)

• 1910.1047 - Ethylene Oxide

• 1910.1048 – Formaldehyde

• 1910.1050 – Methylenedianiline

• 1910.1051 - 1,3-Butadiene

• 1910.1052 - Methylene Chloride

• 1910.1096 – Ionizing Radiation

• 1910.1200 – Hazard Communication

• 1910.1450 - Occupational Exposure to Hazardous Chemicals in Laboratories

Preparedness

• Develop an OSHA compliance calendar

• Ensure all of the required written plans are up to date

• Develop a training matrix

• Keep records organized and ready for inspection

Be Ready!

Be Ready!• Review the OSHA 300

Log

• Conduct internal inspections

• Involve employees to get their buy-in

• Enforce programs such as personal protective equipment, safety devices, etc..

Industrial Client• We did a survey to help identify

potential OSHA compliance issues and to train employees on what to do when they arrive

• We identified numerous issues that needed to addressed by client

• OSHA did a site visit several months later and the facility was found to have no violations in there program

Higher Education Client• The client was visited by OSHA

regarding an employee compliant

• We assisted the client with responding to the complaint and then correcting the issue

• We also trained the staff on what to do when OSHA comes back onsite

• OSHA did a follow up inspection and commended them for the thoroughness of the response

Questions?

Rick Footerfoote@triumvirate.com 617-686-6184

Thank You!

1-888-TEI-WOWS www.triumvirate.com

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