Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS.

Presented By: Scott D. Cole, LEED GA, COSS, CSP

OSHA INSPECTIONS

ObjectivesWhen Can I Expect an OSHA Inspection?How Can I Prepare for an OSHA

Inspection?How Should I Handle an OSHA

Inspection?How Do I Close an OSHA Inspection?

2016 OSHA Citation Structure

Who is OSHA?

$592MM in 2016

7.3% Increase

37,785

Chemical Facilities

Why Would OSHA Inspect?CatastropheEmployee complaintProgrammed inspections

http://www.osha.gov/as/opa/foia/hot_11.html Invitation

Preparing Your OrganizationWritten programDrillsKnow your rights!

What Are My Employees’ Rights?Representation at opening and closing

conferenceRepresentation during the inspectionPrivate interviewsWhistleblowers protection

Managing the InspectionWarm welcome or demand a warrant?IdentificationWhat is the purpose of the inspection?Offer a beverage and a comfortable work

spaceKill them with kindness

The Opening ConferenceWho should be involved?Designate a scribeListenListenListenAnswer direct questionsDocumentation – know what’s required

The Physical InspectionAssemble your best teamPlan a route of travelTake photosFix it ASAPEmployee interviews

Physical ConditionsHousekeepingGuardingFall protectionIlluminationSanitationSignageSafety equipment

DocumentationOSHA logsExposure recordsWritten programs, SOPs, JHAs, etc.Training recordsMedical recordsDiscipline log

Written Programs – Not All-InclusiveHazard

CommunicationsRespiratory ProtectionHearing ConservationLockout / TagoutConfined SpaceBlood Borne

PathogensPPEExcavation Safety

Fire and Emergency Evacuation

Access to Employee Medical Records

Fall ProtectionElectrical SafetyLadder SafetyScaffold SafetyCrane Safety

The Closing ConferenceDesignate a scribeListenListenListenAsk but don’t argueDon’t make promisesThank you

The CitationReviewDocument corrective actions, if any and

postRequest an informal conference

Formal letterFile a Notice of Intent to Contest

15 business daysStep 1 – Administrative Law JudgeStep 2 – Full OSHRCStep 3 – US Circuit Court of Appeals

PenaltiesDependent upon how likely the violation is

to result in serious harm to employees Other-than-serious

$0 - $7,000Serious

$0 – 7,000Repeat and Willful

$0 - $70,000

August 1, 2016 PenaltiesDependent upon how likely the violation is

to result in serious harm to employees Other-than-serious

$0 - $12,000Serious

$0 – 12,000Repeat and Willful

$0 - $125,000

Questions?

THANK YOU

Scott D. Cole, LEED GA, COSS, CSPSteering Committee – Lake County Safety Council

V. President – Northern Ohio Chapter of the American Society of Safety Engineers

President – Cole Safety ServicesBusiness Unit Safety Director – Turner Construction Company

[email protected]