OSHA Inspection

[rexfire]

I was wondering what your policy is in handling a focused OSHA inspection. Say for example an OSHA inspector comes and states he is there to investigate a given machine due to a complaint. Would you drive him around the outside of the plant to the nearest door to go directly to the machine in question or do you just take him through the plant to the machine?

 

[racookpe1978]

I guess it depends on what you want to hide: Is there anything between the plant gate and the machine that you "know" the inspector should not be allowed to see? 8<)

No, I would not recommend you allow him/her unrestricted access to your plant (open the gate and tell him to "walk around until you get done"), but you should be operating correctly and safely as a matter of routine. Since you indicate the inspector is going to be "investigating a complaint" - he/she is going to arrive suspicious and will be deliberating looking for flaws or errors, and, in particular, for any conditions or safety violations you are trying to hide or minimize.

So, follow your plant's published and EXISTING "escorted visitor" safety policies and PPE and training: Give the slideshow or video, make sure he/she has all the right PPE and the right clothing (fireproof/fire resistant clothing/steel-toed shoes, hardhat, goggles, hearing protection, etc.) and then take him to the machine, take him back to the machine, allow time to answer the questions back in the office, etc.)

 

[MiketheEngineer]

You might want to sit down with your lawyer and any safety people you may have to put together a plan for "next time". And there will always be a next time.

Also - you can invite OSHA to come in and inspect and recommend changes to your plant with no penalty. Many companies have done this - because it is fairly quick, easy and much cheaper than fighting fines. And you and your employees know you are doing the best for all involved.

 

[chicopee]

You could always ask for a search warrant which is your constitutional right. If the judge sees no reason for issuing the search warrant, then the OSHA inspector won't get in. If the search warrant is specific as to what you be inspected, then accompany the inspector to the site with no sidetracking. Remember, people provide too much information when an inspector is around, so keep your answers to the point without too much details.

 

[MiketheEngineer]

Good Point - Chicopee

Best answers are "Yes", "No" and "I don't know" THAT IS IT!!!

 

[mcgyvr]

Silly question... Everyone knows you just put a dark sack over their heads on the way to the machine.

The fact you think/might have something to hide bothers me.

 

[rexfire]

I do not have anything to hide, but why invite more scrutiny then you have to. Can you say that every bench grinder you have is set properly all the time? or every bottle is labeled correctly and didn't fall off right before the inspector arrived, etc...

 

[mcgyvr]

No.. but I don't think any level of scrutiny is an issue as far as safety is concerned (as long as they just aren't making rules up as they go) Not to mention they typically aren't total a-holes out to get you.. They realize mistakes/stuff happens. If its a minor issue they typically will just say "hey get a label on that" or whatever and move on. If its something serious that you didn't notice its probably good that they caught it before something happened.

 

[MiketheEngineer]

Agree with mcg - get with OSHA and FIND out more about their programs. It can/does make life simpler.

If you have them voluntary inspect and you CORRECT anything they find - no penalties, no lawsuits, no fines and you can sleep at night.

LOOK INTO IT!!

 

[tomwalz]

They have always been fair to me.

The one time I did get gigged it was over paperwork.

Have your posters and accident records up in the lunch room or by the time clock.

Make sure all chemical containers are labeled. We wrap a label on squeeze bottles then cover it with clear packing tape.

Make sure you have all your MSDS sheets. Make sure your employees know about them. Post area specific warning signs in all danger areas. A great site for that is the SIRI MSDS Index.

We use Wisha in Washington State. I have two binders full of regulations in official safety green. Sitting next to my desk is a file cabinet and the top drawer is outlined in official safety green tape.

When the inspector comes in the first thing I do is show him the paperwork. I mention that I even have MSDS sheets for hand soap.

I want the guy to know I have made a real effort to comply.

Tom


Thomas J. Walz
Carbide Processors, Inc.

http://www.carbideprocessors.com

Good engineering starts with a Grainger Catalog.

 

[safetysupervisor]

I think you should take him through the plant besides going via a by-pass door, because it'll create good impression in front of OSHA officer and also you might come to know the flaws of the safety management. Because what I think, employee safety is first priority for you too rather than little fines charged by the officer.

 

[786392]

Moreover it creates improvement and self evaluation opportunities as well

Best Regards
Qalander(Chem)

 

[loucapa]

rexfire, im curious as to what happened. What i do know of inspections, is that if allowed into a site they are permitted to identify and cite you for any hazards observed - what they term 'plain site doctrine'. Also unless the alternative and less intrusive entry is not remote like walking 1/2 mile to get to a spot 300 ft away then you may have no choice but to take them through your peripheral ops/space. I recommend never to ask for a permit, since historically this leads to a much larger scope of inspection and normally more substantial fines given the likelihood of more other-than-serious citations (hopefully). I dont mention serious or willful because i would hope your company would have addressed those as you indicated in your thread. Its unfortunate most companies usually delegate EHS related matters to line supervisors or managers as collateral duties when in fact they have no right to be the designated competent authority on EHS related matters. Anyways i hope it went well

 

[loucapa]

I just notice an omission in my paragraph. Prior to the "its unfortunate...." i had stated that OSHA inspections usually do result in citations given both the lack of continuity between company interpretations of the standards and OSHAs as well as the often poorly funded discipline (among a rash of other potential reasons....); however the gravity of those are dependent on your companies willingness to abate and normally smaller companies do not observe the ROI on safety and therefore do not fund appropriately and ..... This is not at all specific to your company nor your situation this is just a general view.