What to do to prepare for an OSHA Audit

Meet the Speaker

Rick 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 Violations

1. Fall Protection

2. Hazard Communication

3. Scaffolding

4. Respiratory Protection

5. Lockout/Tagout

Top 10 Violations6. Powered Industrial Trucks

7. Ladders

8. Electrical

9. Machine Guarding

10. Electrical, General

Requirements

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 Preparedness

Coordinating 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: Logistics

and 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 Foote

rfoote@triumvirate.com

617-686-6184

Thank You!

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

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