One of Alper’s Safety & Loss Control Experts, Terry Konell, offers his insight into the new OSHA reporting guidelines put in place
on January 1, 2015.
Since the new reporting guidelines came into play as of January 1, 2015, OSHA has only inspected 40% of violations reported to OSHA. Because of this, OSHA is going to conduct more “quality” inspections in 2016 and will assign priorities to the inspection. Translated, this means OSHA is going to dig even deeper into your safety policies, practices and programs. The new priorities will be based on the nature of the inspection, and if the company has had prior OSHA activity to including repeats, willfuls, or been non-cooperative in the past.
Bottom line, if OSHA conducts an inspection at your facility, your job is to keep them focused on why they came to your establishment in the first place. You need to ensure they do not expand the inspection beyond the scope of the inspection.
Example: I had a client who reported a major accident to OSHA within the 24 hour guidelines. OSHA showed up for the accident inspection. During the employee interviews, the question of working with chemicals came up, causing the inspection to expand. On the 180th day, OSHA hand-delivered a citation not for the accident (what brought them there in the first place) but for HAZCOM. They found the one employee who was not trained on HAZCOM, which resulted in a $2,400 citation.
My advice to you is to be prepared when OSHA shows up at your door. I taught the OSHA inspectors, and they are taught to manage the inspection and to expand, expand, expand. As the employer, you need to understand that it is still your business, but you have to co-operate with OSHA when they arrive. Never lie or deceive, and most importantly, do your best to keep them focused on the scope and application of their visit.
Here is an article about OSHA’S “new” inspection strategy. Remember, you do not want OSHA to set up camp at you facility! By the way, the article mentions “routine inspection.” THERE IS NO SUCH THING AS A ROUTINE INSPECTION BY OSHA!
Dust off that old safety manual and get your policies and procedures up to date. Train your employees as required, and document, document, document. If you need any assistance on your written polices or procedures do not hesitate to contact Alper Services.
Contact John Zitko, Director of CMS, at (312) 654-4254 or JZitko@alperservices.com to arrange a review by Terry Konell or one of Alper’s other OSHA experts.