How to Prepare Your Facility For an OSHA Inspection
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1 Be prepared for OSHA! Patric E. McCon, CSP, CFPS, CHMM Sr. Consultant Zurich Services Corporation
2 Today s discussion preparing your facility for an OSHA compliance inspection; managing the inspection when (not if) it happens; what to do after the inspector leaves; how to reduce the odds of inspection. 2
3 Why does OSHA show up? catastrophe complaint programmed inspection invitation 3
4 Preparing the facility aspects to examine: written programs training recordkeeping physical conditions 4
5 Preparation - written programs include but not limited to: BBP HazCom respiratory protection hearing conservation lockout confined spaces 5
6 Preparation - training (see OSHA 2254) fire extinguishers care, use, limitations of ppe, respirators, earplugs HazCom specific toxics (Subpart Z) powered industrial trucks electrical safety related work practices others 6
7 Preparation - recordkeeping OSHA Log OSHA 301 or equivalent exposure records training records medical records 7
8 Preparation - physical conditions commitment to housekeeping and maintenance machine guarding fall protection illumination order sanitation signage safety equipment ppe enforcement 8
9 They re at the door! managing the inspection there will be no advance notice the employer has rights the employees have rights 9
10 Managing the inspection invite them in or ask for a warrant? ask for identification call to confirm ask the scope marshal the troops be nice! 10
11 Managing the inspection opening conference listen lots, talk little paperwork request/review provide documents that are required defer requests for other documents be nice! 11
12 Managing the inspection the physical inspection who goes along? how do they get there? take notes take photos take measurements employee interviews fix things be nice! 12
13 Managing the inspection the closing conference ask questions, but don t argue listen! take notes don t make promises or commitments be nice! 13
14 After the inspection #1 fix what was found before the citation arrives when the citation comes: review it post it request an informal conference file Notice of Intent to Contest if you wish 14
15 Employee rights representation at opening/closing conferences representation during inspection private interviews with CSHO whistleblower protection 15
16 Reducing the odds one approach: participate in OSHA voluntary programs VPP, etc. reduces odds of programmed inspections 16
17 Reducing the odds a better approach: management commitment effective EHS process employee engagement clean, well-maintained workplace employees with a high level of satisfaction 17
18 Conclusion 18
19 Questions/comments? 19
20 Thanks!
21 2008 Zurich Services Corporation. All rights reserved. The information in this publication and presentation was compiled by Zurich Services Corporation from sources believed to be reliable. Further, all sample policies and procedures herein should serve as a guideline which you can use to create your own policies and procedures. We trust that you will customize these samples to reflect your own operations and believe that these samples may serve as a helpful platform for this endeavor. Any and all information contained herein is not intended to constitute legal advice and accordingly, you should consult with your own attorneys when developing programs and policies. We do not guarantee the accuracy of this information or any results and further assume no liability in connection with this publication and presentation and sample policies and procedures, including any information, methods or safety suggestions contained herein. Moreover, Zurich Services Corporation reminds you that this cannot be assumed to contain every acceptable safety and compliance procedure or that additional procedures might not be appropriate under the circumstances. The subject matter of this publication and presentation is not tied to any specific insurance product nor will adopting these policies and procedures ensure coverage under any insurance policy. 21
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