After the opening conference, the compliance officer and accompanying representatives proceed through the establishment to inspect work areas for safety or health hazards.
The route and duration of the inspection are determined by the compliance officer. During the inspection, the officer will:
-
Observe safety and health conditions and practices,
-
Consult with employees,
-
Take photos and instrument readings,
-
Examine records,
-
Collect air samples,
-
Measure noise levels,
-
Survey existing engineering controls, and
-
Monitor employee exposure to toxic fumes, gases and dusts.
Trade Secrets
Trade secrets observed by the compliance officer will be kept confidential. An inspector who releases confidential information without authorization is subject to a $1,000 fine and/or one year in jail. The employer may require that the employee representative have confidential clearance for any area in question.
Consulting with Employees
Employees are consulted during the inspection tour. The compliance officer may stop and question workers, in private, about safety and health conditions and practices in their workplaces. While talking with employees, the compliance officer makes every effort to minimize any work interruptions. Each employee is protected, under the OSH Act, from discrimination for exercising his or her safety and health rights.
Recordkeeping
OSHA places special importance on posting and recordkeeping. The compliance officer will inspect records of deaths, injuries, and illnesses which the employer is required to keep. The officer will check to see that a copy of the totals from the last page of OSHA 200 Log or the OSHA 300A Summary have been posted and that the OSHA 2203 or OSHA 3165 workplace poster is prominently displayed. Where records of employee exposure to toxic substances and harmful physical agents have been required, they are also examined for compliance with the recordkeeping requirements.
The compliance officer also explains that while the following items are not required for all OSHA standards they should be recorded to accurately monitor and assess occupational hazards.
Initial and periodic monitoring for operations involving exposure, including:
-
Date of measurement;
-
Sampling and analytical methods used and evidence of their accuracy;
-
Number, duration, and results of samples taken;
-
Type of respiratory protective devices worn; and
-
Name, social security number, and the results of all employee exposure measurements.
This record should be kept for 30 years.
Employee physical/medical examinations, including:
-
Name and social security number of the employee;
-
Physician's written opinions;
-
Any employee medical complaints related to exposure to toxic substances; and
-
Information provided to the examining physician.
These records should be maintained for the duration of employment plus 30 years.
Employee training records should be kept for one year beyond the last date of employment of that employee.
Communicating Hazards
The compliance officer also explains the requirements of the Hazard Communication Standard which requires employers to establish a written, comprehensive hazard communication program covering provisions for container labeling, material safety data sheets, and an employee training program. The program must contain a list of the hazardous chemicals in each work area and the means the employer will use to inform employees of the hazards of non-routine tasks.
Unsafe Workplace Conditions
During the course of the inspection, the compliance officer will point out to the employer any unsafe or unhealthful working conditions observed. At the same time, the compliance officer will discuss possible corrective action if the employer so desires.
Some apparent violations detected by the compliance officer can be corrected immediately. When they are corrected on the spot, the compliance officer records such corrections to help in judging the employer's good faith in compliance. Even though corrected, however, the apparent violations may still serve as the basis for a citation and, if appropriate, a notice of proposed penalty.
An inspection tour may cover part or all of an establishment, even if the inspection resulted from a specific complaint, fatality or catastrophe
No comments:
Post a Comment