What is OSHA Looking for When They Visit Your Facility or Jobsite?
I am asked this question repeatedly: “What will OSHA look for if I get inspected?’” Honestly, there’s no simple answer. The hazards inside your facility or jobsite are as unique as you, your company, and the product or service you provide.
A good starting point to determine where OSHA enforcement will focus its efforts when it comes to your location can be found online at OSHA.gov:
OSHA’s Top 10 most frequently cited standards in 2012 (October 1, 2011 through September 30, 2012):
- Fall protection, construction (29 CFR 1926.501)
- Hazard communication standard, general industry (29 CFR 1910.1200)
- Scaffolding, general requirements, construction (29 CFR 1926.451)
- Respiratory protection, general industry (29 CFR 1910.134)
- Control of hazardous energy (lockout/tagout), general industry (29 CFR 1910.147)
- Powered industrial trucks, general industry (29 CFR 1910.178)
- Ladders, construction (29 CFR 1926.1053)
- Electrical, wiring methods, components and equipment, general industry (29 CFR 1910.305)
- Machines, general requirements, general industry (29 CFR 1910.212)
- Electrical systems design, general requirements, general industry (29 CFR 1910.303)
As you can see from the list, there is a good mix of citations related to construction, general industry and standards that apply to both, such as Hazard Communication and powered industrial trucks.
Now compare the above hazards to those frequently identified by our USF SafetyFlorida consultants, and it is quite obvious which hazards are the most commonly seen at a jobsite or facility.
Hazards identified by USF SafetyFlorida Consultants 2009-2012
- Electrical, wiring methods, components and equipment
- Electrical systems design, general requirements
- Hazard communication standard
- Respiratory protection
- Control of hazardous energy (lockout/tagout)
- Portable fire extinguishers
- Personal protective equipment
- Machines, general requirements
- Occupational noise exposure
- Powered industrial trucks
Whether your company falls under general industry, construction or both, it would be best to focus on those areas that have been noted in both lists.
Thinking like a Compliance Officer
From my experience in speaking with employers whose businesses have been inspected, most compliance officers will take the path of least resistance. If an officer is noting obvious hazards throughout the facility/worksite, there is a good chance that is where they will focus their inspection. For example, if many unlabeled or incorrectly labeled containers are found, more than likely the inspector will focus on your hazard communication program and training.
Therefore, some of the first steps you can take in an effort to eliminate hazards within the workplace are training and inspections. However, before effective inspections can be performed, you must first gain the knowledge of hazard recognition. This can be acquired through training that can be provided by our consultants or the USF OSHA Training Institute Education Center (http://usfoticenter.org/). Inspection should be performed on a regularly scheduled basis. How often really depends on the work being performed and the environment. If you are a small manufacturer, monthly would be acceptable; however, a construction site should be inspected daily since the work environment is in a constant state of change. If possible, inspections should be performed by more than one individual, in an effort to eliminate complacency or “pencil whipping” the forms. Fresh eyes normally notice items that are being taken for granted on a daily basis.
Another common question I am asked by many employers is “How do I know which standards apply to me?” Some standards are easier to pinpoint than others. For example, if you use forklifts and chemicals at your location, then the powered industrial trucks and hazard communication standards will apply to your establishment. However, as the employer, you must know what is associated with each standard, which could include a written program, training, etc.
For other standards it can be much more complicated in not just determining if the standard applies, but which parts of the standard. Your best bet in determining which standard, training and/or written programs apply would be to schedule a free consultation with one of our USF SafetyFlorida Consultants. Not only will our consultants assist you with understanding and interpreting the standards, they can also help you in identifying hazards in your workplace, reviewing your injuries for trends, developing a safety culture, and possibly assist you in lowering your workers’ compensation cost.
You can request a free consultation here http://www.usfsafetyflorida.com/Consultation-Request-Form or contact us at 1-866-273-1105.
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