Play a starring role in next OSHA inspection
It is something that involves the well-being of employees and your company's bottom line. It can demonstrate your value in a way nothing else can. However, many times occupational health professionals don't even participate when an Occupational Safety & Health Administration (OSHA) inspection occurs. Why not take the opposite approach?
Colleen Hasler, MS, RN, COHN-S, a risk manager at M3, a Madison, WI-based company specializing in health, safety and environmental risks, says to do these things during an onsite OSHA inspection, whether scheduled or unscheduled:
Perform air sampling and noise monitoring and take photographs.
"When OSHA takes a picture, it is critical for the employer to take a picture for legal purposes. This is also true for any type of industrial hygiene sampling," Hasler explains.
Hasler notes that OSHA's compliance health and safety officers (CHSOs) handle either the safety or industrial hygiene areas. "So it is important for you to be competent in both," she says.
Ask pertinent questions when the CHSOs are addressing a compliance issue.
"You need to be able to reference the details of the related standard," says Hasler. "By knowing this information, you can prevent a potential citation." If lockout/tagout compliance is the issue, you'll need to know the steps to de-energize equipment, lock equipment out, and re-energize equipment specific to the various energy sources including electric, pneumatic, and hydraulic.
Keep a record of any conversations with CHSOs, equipment looked at, employees spoken to, and any employer documentation that was reviewed.
Ask prudent questions of CHSOs.
During the opening conference, Hasler says to ask three questions: What will the scope of the inspection entail? What areas will be inspected? How long is the inspection expected to take?
The closing conference, says Hasler, is "the last opportunity for the employer to provide information to avert an OSHA citation. It is important to understand the specific alleged OSHA violations and be knowledgeable in refuting them. At times, implementing immediate corrective action becomes critical."
The next step is to provide upper management with all of the relevant information from the OSHA closing conference, says Hasler. They will need to understand their potential financial exposure.
In order to identify discrepancies in what the inspector is claiming, there is no substitute for having an in-depth comprehension on the relevant standards.
"Interpreting the standard isn't always black and white. It depends on how the technical verbiage is viewed," says Hasler. "Your role is to be an advocate for the employer in demonstrating compliance."
It is something that involves the well-being of employees and your company's bottom line. It can demonstrate your value in a way nothing else can. However, many times occupational health professionals don't even participate when an Occupational Safety & Health Administration (OSHA) inspection occurs. Why not take the opposite approach?You have reached your article limit for the month. Subscribe now to access this article plus other member-only content.
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