The Occupational Safety and Health Administration (OSHA) sets the baseline for occupational safety and health in the United States. All companies are required to do at least the minimum’s set forth in the OSHA regulations or face civil (or potentially criminal) action. It is important to remember that OSHA sets the minimum that you must do, not the best practices that will make your organization succeed. A visit by a representative of OSHA can be a frightening experience for the unprepared, which can result in fines (some very large) and even placement on special watch lists by this federal organization.
Are You Prepared?
The time to prepare for an OSHA inspection is obviously before they show up at your door. Some organizations gamble that OSHA will be too busy to bother with them. Others don’t care, figuring that any fine is just part of the cost of doing business. This is not a good gamble. Too many things can happen to bring your company to OSHA’s attention. Even a news story about a good thing happening can bring your company to OSHA’s attention, triggering a visit. You just don’t know when it is going to happen. And once they are there, your lack of preparation will show, possibly leading to a deepening investigation and resulting fines.
However, OSHA fines are just the beginning. An unsafe workplace leads to additional costs, such as worker compensation increases, poor morale, legal issues, quality control and production issues due to trained workers being out on injury leave, damage to equipment and product……well, the list goes on and on. Remember, OSHA sets the minimum. Are you or your organization satisfied to do the minimum in any other aspect of your business? If not, then why would you be satisfied to do below the minimum in occupational safety? Successfully companies with world class production and world class quality also usually have world class safety and health programs. They don’t worry about OSHA inspections, as they go above and beyond the OSHA regulations to protect their employees and their company. So, which do you want to be?
We will assist you in preparing for not only an OSHA inspection, but in building a world class safety and health program that will assist you in moving your company forward. We will review all your written programs to insure they meet the OSHA requirements. Programs such as permit required confined space, lockout/tagout, hazard communication, respirator training, hearing conservation and many other programs have specific requirements on what must be in writing, when it should be reviewed and how it must be implemented. Recordkeeping of recordable accidents on the OSHA 300 log, as well as proper investigation of those recordable injuries must also be done in a timely and complete manner.
The workplace must be inspected to identify hazards and potential OSHA violations. This may include machine guarding issues, personal protective equipment usage, fall protection, ventilation, handling and storage of flammable liquids, handling and storage of hazardous chemicals, housekeeping, walking and working surfaces and much more. Industrial and construction job sites are constantly changing, as are the hazards of those work sites, so a review of the safety management system should be conducted to determine the flexibility and accountability of the system to respond to that changing environment.
For those looking to go beyond OSHA compliance, we can also work with your company in developing a behavior based safety program. OSHA primarily addressed workplace conditions, however, most accidents are caused by employee behaviors (90%behaviors/10% conditions, although that ratio can vary, depending on who you listen to). And it isn’t just employee behavior, but also management behaviors that factor into this. Just addressing conditions will not necessarily make your workplace safer, although it may make it OSHA compliant. If you are trying to be world class in your safety and health program, you need to address behaviors also. We are there to be your partner in assisting you to not only meet OSHA requirements, but to build towards that world class organization you want and need.
Another part of OSHA compliance is the need to train your employees and supervisors in the safety programs that affect them as well as the safety techniques needed to do their job efficiently and safely. We provide a wide array of training classes specifically tailored to your situation and needs. We also assist you with the documentation that must be kept to prove that the training was done.
Documentation is very important in the face of any compliance activity or investigation by OSHA or by the Ohio Public Employment Risk Reduction Program (PERRP). Failure to properly document training is a common finding in compliance activities or investigations and can lead to significant fines and penalties.
Review the training offerings on this page. If you do not see what you want, contact us and we will design a training program for your particular needs. We have OSHA authorized instructors in m any fields, as well as technical experts to assist you in whatever your safety needs may be.
Inspections and Investigations
OSHA (or PERRP) is at the door! They have shown you their identification and have demanded records and access to your workplace. What do you do next? The answer you give may have significant ramifications to you and to your company. OSHA and PERRP may show up for a variety of reasons, from a scheduled inspection to a fatality investigation. Employee complaints, placement on an emphasis list due to your industry, refusal of an employee to perform an operation he/she believes to be unsafe and many other reasons may bring them to your door. You can chooses to deny them entry (not a good idea), forcing them to get a court order to gain entry. You can give them everything they want and let them roam freely through your workplace (this may also not be a good idea). Or, you can call your safety partners to assist you through this process.
OSHA and PERRP will wait a reasonable amount of time for a representative to arrive before conducting their business. If you have a partnership with us, we will arrive at your worksite as quickly as possible to insure that they get the information they need, see exactly what they need to see and document every step they take through the process. We will be there to answer questions regarding any work or training we have done with you and to keep the inspection/investigation focused solely on the matter at hand. This is not something you want to go through alone and your safety partners at ESS will be there to assist you through it.
OSHA offers a consultative service call OSHA On-Site Consultation. While this service is free, you must correct any safety hazards identified within a certain time frame or they will notify the local OSHA service and they will commence enforcement activities. They are helpful, but can also present a potential liability. The SHARP program is used by many companies to improve their safety process. It is a very intense safety process improvement and you will need support in achieving this goal. We can assist you in reaching this impressive goal.
OSHA On-Site Consultation’s services include free on-site safety inspections and consultation, safety program assistance, safety and hygiene training or seminars and printed and electronic resources. Unlike the federal OSHA program, OSHA On-Site Consultation does not have right of entry to a workplace; and it does not issue citations or fines. An employer must request the service, and has a mutually agreed-upon time frame within which to correct any safety hazards identified.
In Ohio employers participate in OSHA’s Safety and Health Achievement Recognition Program (SHARP). This program is designed to provide incentives and support to smaller, high-hazard employers to develop, implement and continuously improve effective safety and health programs at their work site(s). SHARP provides for recognition of employers who have demonstrated exemplary achievements in workplace safety and health. For more information about SHARP, please visit OSHA’s Web site.
Dealing with OSHA and PERRP can be a challenging proposition for even a company with an excellent safety program. If you are not prepared, it can have a terrible impact on your company. We are here to be your safety partner and help you deal with the government safety agencies. Through compliance assistance, training and inspections/investigations, we are here to stand by you and insure you are fairly represented when necessary. The important thing is to build a world class safety and health program that will protect your company, improve your bottom line and leave no room for OSHA or any other agency to complain about your safety and health efforts.