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Notas do Editor
- Let’s focus on making your documents pass the first glance test. Prior to setting foot on the factory floor, the CSHO may ask to review certain key programs. Let’s use Hazard Communication for this example as it generally applies to all facilities. First, this standard requires a written program. Do you have one? If it’s canned, has it been made company specific? For example, on the title page does it have your company name and address, does the terminology match that of your organization? Does the policy meet the requirements of the standard? Does it discuss labeling, training, msds preparation and . Moving out to the plant floor, are containers labeled? Does your policy discuss immediate use container labeling? For instance if an employee siphons oil from a 55 gallon drum for lubrication, is that secondary (or immediate use) container labeled? As OSHA has an exception for immediate use, labeling might not be required unless your program specifies that ALL containers will be labeled. If your policy goes above and beyond OSHA requirements, you will be held to the more strict standard. Lastly if use of HMIS is employed as the labeling process, do all employees know how the process works? Can they explain the system? If you have effective and engaging training, your employees should be able to explain the system, describe or actually obtain an MSDS for a product on the floor and tell the CSHO how to where the written program is kept. Adults are only able to retain about 10% of new information, so having hands on demonstrations along with classroom instruction will help cement the learning. Additionally while not specifically required, having sign in sheets for the training session will assist in providing proof that employees have been trained.
- As with our example of the immediate use chemical, some corporations require all units to adhere to the same standards. As I mentioned if your policy goes above and beyond OSHA requirements, you will be held to the more strict standard. So how do you convince Corporate to settle for the OSHA standard? Unless you have some undue influence on Corporate, this situation is one you likely cannot change. Let’s use this to your advantage when dealing with a CSHO. Your company, for whatever reason, has decided to implement a more stringent policy. If the CSHO is evaluating one such program, you mention that the commitment of the business is to providing a safe and healthy work environment. For this reason, we have decided that all immediate use containers will be labeled. We realize that OSHA has an exception, however, we also recognize that mistakes can be made and the possibility of having an unattended, unlabeled container exists. For the health of our employees, we opt for the more stringent policy. During the walk around inspection, with this understanding, the CSHO may look more favorably on the facility and allow an immediate correction if an unlabeled container is found. If you are using a compliance instruction or relying on a letter of interpretation as the basis of your programs, have copies of these documents available. For example letters of interpretation are posted on the OSHA web page, however without warning or announcement, these documents call be pulled. If you do not have a saved or hard copy of the document, you may not be able to convince a CSHO that your program/policy was founded on sound OSHA information. Further, with differing administrations, interpretation can change drastically. Not all CSHO are technically competent. Take me for example, I was a health CSHO, my training and education is in industrial hygiene. On several of my first inspections, it is completely possible that I walked straight past LOTO violations. However after reading through a company policy, I was able to stop en-route to a complaint item and ask specific questions about a LOTO operation being conducted (incorrectly I might add) which resulted in a citation and penalty. In this case, because the company had a very good LOTO program and it’s procedures were outlined, I was able to determine that the training element was lacking as the operator did not understand the term exclusive control.