OSHA violations are expensive and time consuming to resolve. It is significantly cheaper and easier to create an OSHA-compliant workplace from the start. Ensuring OSHA compliance requires a complete understanding of the OSHA requirements and a complete assessment of your current workplace. In this webinar, our expert will walk you through the key steps to creating an OSHA-compliant workplace.
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During this Webinar
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✓ Communicate via the questions tab in your webinar panel.
✓ Unanswered questions will be responded to personally after the
webinar.
✓ Webinar recording and slides will be emailed to you tomorrow.
6. Introduction
• An agency within the Department of Labor.
• “Assure safe and healthy working conditions for working
men and women by setting and enforcing standards and
by providing training, outreach, education and assistance.”
• OSHA covers most private sector employers in all 50
states, the District of Columbia, and other U.S.
jurisdictions—either directly through federal OSHA or
through an OSHA approved state plan.
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7. OSHA Review
• OSHA General Industry Standards are
covered under 29 CFR 1910
• The Standard has 20 subparts which
address different components of the work
environment
• Letters of Interpretation are searchable and
available for review
• Employers are responsible for determining
which components of the standard apply to
their operations
• Employers are responsible for recording and
reporting incidents as required by OSHA
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8. OSHA Review
The General Duty Clause states:
(a)Each employer –
(1)shall furnish to each of his employees employment and a place of
employment which are free from recognized hazards that are causing or are
likely to cause death or serious physical harm to his employees;
(2)shall comply with occupational safety and health standards promulgated
under this Act.
Reference: OSH Act of 1970, Section 5. Duties
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9. OSHA Review
The General Duty Clause states:
(b) Each employee shall comply with occupational safety and
health standards and all rules, regulations, and orders issued
pursuant to this Act which are applicable to his own actions and
conduct.
Reference: OSH Act of 1970, Section 5. Duties
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10. OSHA Review
Inspections
• Can be initiated by a number of events
▪ OSHA initiatives
▪ Injuries/deaths
▪ Complaint filed
• Maintaining a compliant workplace, and
having a team prepared to handle an
inspection are vital
• Companies should have staff prepared
and trained on the inspection process to
facilitate the workplace inspection
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11. OSHA Review
Inspection process:
• Review of inspection history
• Inspector arrival
• Opening conference
• Review of records
• Walkaround inspection
• Interviews
• Closing conference
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12. OSHA Review
After the inspection:
• Notification of findings and citations
• Finding abatement
• Informal conference
• Fines and public announcements
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13. OSHA Review
Inspections can result in:
• Public record of the inspection
• Public notification
• Fines
• Imprisonment for repeated willful
violations
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16. Assessing Your Workplace
Know the regulations
• All OSHA standards are available on the OSHA website. It is the
employer’s responsibility to comply with all applicable
requirements.
• All programs must be specific to your workplace, and regularly
maintained, inspected, and documented to ensure compliance.
• As processes change, new regulations may apply.
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17. Assessing Your Workplace
Documentation
• OSHA forms
▪ OSHA 300 Form
▪ OSHA 300a Form
▪ OSHA 301 or other incident investigation
documentation
• Program documentation
▪ Lockout tagout
▪ Hot work
▪ And more…
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18. Assessing Your Workplace
Documentation
• Inspection documentation
▪ SOPs
▪ Eyewash, fire extinguisher
▪ Compliance inspections (laboratories,
machine guarding, PPE usage, Etc.)
• Sign-in sheets and minutes
▪ Trainings
▪ Safety committee meetings
▪ New hire onboarding and job-specific training
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Assessing Your Workplace
Documentation
• Industrial hygiene results
▪ Air sampling
▪ Formaldehyde
▪ Noise
• Voluntary programs
▪ Respirator
▪ Hearing protection
• Hazard Communication
▪ Safety data sheets
▪ Labels
▪ Program
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20. Assessing Your
Workplace
Training
• Trainer must be qualified
• All workers must be trained on the
hazards of their workplace before they
start work (this includes employees,
temporary workers, contractors, etc.)
• Training is required for all SOPs
• Retraining must occur at regular
intervals
• Workers must have the opportunity to
speak to the trainer and ask questions,
online and video training is not ideal
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21. Assessing Your Workplace
Procedures
• Standard operating procedures must be
developed and comply with OSHA
standards
• Procedures must be specific to the
workplace
• Procedures must be maintained
• Workers must know where to locate
procedures and have open access to
them
• Procedures must be reviewed annually
(at least) to keep them up to date
• “Say what you do and do what you say”
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22. Assessing Your Workplace
Reporting - Know your reporting requirements!
• 300 Form
• Hospitalization
• Amputation
• Loss of eyesight
• Point of operation injury
• Loss of consciousness
• And more…
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23. Assessing Your
Workplace
Inspection Preparedness
• The best way to prepare for an inspection
is to maintain a fully compliant EHS
program, and continuously work to prevent
reduce and prevent injuries
• Know what to expect
• Have a back up for the EHS manager
• Provide reception with instructions on what
to do when an OSHA inspector arrives
• Maintain documentation and comply with
record retention requirements
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26. Becoming Compliant
Making a plan
• List out your known non-compliances
• Identify areas where you may have gaps
• Work with an expert to ensure all non-
compliances are identified
• Depending on the workplace, it can take
years to build up a fully compliant EHS
program.
• Once you know what you need to do, set
goals and make them a priority.
• Management support has a strong impact on
the workplace’s ability to achieve
compliance.
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27. Becoming Compliant
Prioritization
• Programs and procedures must be
developed before they can be
implemented
• Training will be needed to introduce
employees to the new programs and
procedures
• Upkeep documentation and inspections
to ensure continual compliance
Where to start
• Address areas with history of injuries
first
• Look at high risk areas and make them
a priority
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28. Becoming Compliant
• Management buy in
▪ Management buy in is a huge indicator of the
potential success of a safety program
▪ If you need to work with your company’s
management team to increase buy in, look at
cost benefit analysis, workers compensation
costs, past citations, potential citations if
workplace was inspected by OSHA
• Employee buy in
▪ Keep employees involved in program
development
▪ Ask for their input
▪ Listen to their concerns
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29. Becoming Compliant
• If you are not an OSHA expert, consider
working with someone who can help.
• Gap Assessments include a full review of
your workplace with recommendations on
how to achieve compliance.
• They can save you time, money, and
frustration, while giving you a full look at the
areas where your company’s safety
program is not compliant with OSHA and
EPA requirements.
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31. Program Maintenance
Once compliance is achieved, it must be maintained.
Program maintenance involves:
• Retraining
• Answering questions
• Evaluating new procedures and equipment
• Inspections
• Addressing inspection findings
• Incident investigation
• Onboarding
• Documentation upkeep
• Measurement of EHS key performance indicators
• Developing new programs
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32. In Summary
• All workplaces need to be aware of the OSHA standards that
apply to them.
• Compliance requires effort, expertise, and constant
maintenance. The benefit is:
▪ A reduction in employee injuries
▪ Avoiding OSHA visits
▪ Saving money in fines and workers compensation
▪ Protecting the company image
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