| Surviving an OSHA Inspection |
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SURVIVING AN OSHA INSPECTION
(With the caveat that state and other inspections are different)
Major Regulatory Interest: Unless they're investigating a fatality, complaint, or other major issue, most regulators are primarily interested in five things:
Records The inspector's first stop. They're interested in your Agency OSHA poster (usually called the OSHA 2203, actually the AD-1010), the annual accident log (in Federal workplaces often mistakenly called by its industry name, the "OSHA 200 Log"), and other records that back up your programs: training meeting records, safety committee minutes, records of safety inspections (and fixes!), financial expenditures, etc.
If your records are conveniently found (demonstrating to the inspector that you refer to them frequently enough to know immediately where they're kept), if they're in some semblance of order, and if they appear to be genuine (i.e., the names on the safety meeting sign-in sheets should not be in the same color ink, and handwriting), you've established the atmosphere for a fairly light handed inspection.
Written Programs They will want to see documentation on the major programs. ARS Manual 230 gives general guidance on most everything you'll need, but the inspector will expect location-specific programs for: Hazard Communication and Community Right-to-Know, facilities self protection and emergency planning, personal protective equipment (including respiratory), lockout/tagout, chemical hygiene, bloodborne pathogens (if applicable), hearing conservation, training, and confined space entry.
Management They will want to see responsibilities of management and staff, including
Accountability Signs that your management supports the programs. These are outlined in ARS Manual 230, and can be customized for your location programs.
Employee Awareness Although the inspector may ask employees what they know about your safety program, two things will help demonstrate good awareness:
1. Records of training, with a list of attendees and a test. Many regs require regulation-specific training
2. A good signage program around the lab - hazards well marked and identified, safety tips, safety posters, appropriate signs (e.g., NRC, biohazard, etc.) for your special hazards.
Obvious Hazards Most inspectors are generalists. Unless your inspector has specialized technical knowledge, or unless you have some especially eye catching operation, most inspectors will concentrate on obvious, easily remedied hazards.
| PROGRAM | MANUAL 230 | YOUR 1ST CONTACT | COMMENTS |
Accident Statistics | A-IV.H | APS, ASHM |
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| Asbestos Abatement | C-III | AOE, ASHM |
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| Biological Safety ** | D-IV.T | Bio, ASHM | Mike Kiley on the National Program Staff oversees program. Oriented toward lab design & practices. |
Bloodborne Pathogens** (AIDS, Hepatitis B, etc.) |
| ASHM, Bio | ASHMs tend to take the lead on this, in consultation with Mike Kiley |
CERCLA | D-IV.M | ASHM | Comprehensive Environmental Response, Compensation, and Liability Act - Cleanup of contaminated sites |
Chemical Hygiene* | C-VIII | ASHM | Object: Protect employees from chem exposures |
Clean Water Act | D-IV | ASHM |
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| Community Right-to-Know* | D-IV | ASHM | Object: Notify communities and emergency responders of our chemical hazards |
Confined Space Entry** | C-VII | ASHM |
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| Design/Construct | Man 242.1 | AOE | Build safety into your lab from ground up |
EAP | B-II | APS | Employee Assistance Program - Psychological help |
Emergency planning |
| ASHM, CEPS |
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| Enviro Management | D | CEPS, ASHM |
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| Facilities self protection* |
| P&P | Most facilities use GSA generic FSP plan |
Fuel Storage Tanks* | D-IV | ASHM, CEPS, AOE | We must fix or replace leakers, and install appropriate spill and leak equipment on all |
Fume Hood/Ventilation | D-IV | ASHM | Helpful inspection information also contained in old (and outdated) ARS Manual 232.1 |
Hazard Communication* | C-IV | ASHM, CEPS | Object: Advise employees of chemicals and other hazards at their worksite |
Hazwaste Management* | D-IV.H, ff. | ASHM, CEPS | Chemical disposal, primarily |
HazWaste Cleanup, HWC | D-II.E | ASHM/CEPS, SHEMB | HWC provides $ for cleanup of past environmental sins, with out-of-agency funds. |
Hearing Conservation | C-VI | ASHM | Whatdja say? |
Industrial Safety |
| ASHM | You name it, the ASHM does it |
Industrial Hygiene | C | ASHM, CEPS |
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| Inspection/Abatement | A-VI | ASHM, CEPS | A revised ARS 404 self inspection form is in next-to-final draft |
Laboratory Safety | D-IV.R, ff. | ASHM, CEPS |
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| Life Safety Codes |
| AOE, ASHM | From the Natl Fire Protection Assn fire codes |
Lockout/tagout** | C-VII | ASHM | Object: Control energy during maintenance |
Manual 230.0 | Duh... | ASHM, CEPS | Revised & updated manual soon to be issued |
National Environmental Policy Act | C-II.C | AOE, ASHM, CEPS | NEPA - environmental assessments for construction & major research |
Occupational Health Maintenance Program | B | ASHM, APS | The OHMP matrix from 1983's Manual 235.1 is still in effect...and not reproduced in Manual 230.0! |
OWCP | A-IV.H | APS | Workers' Compensation |
Personal protective equipment* | A-V.E | ASHM, CEPS | You must perform written risk assessments to determine the type of PPE your people need |
Pesticide Management | D-III.J | ASHM, CEPS | Manual 230 not yet updated to include Pesticide Worker Protection Standard |
Radiation Safety | D-IV.V | RSS | In some Areas, the ASHM/CEPS assist, but in all cases, RSS has primary jurisdiction |
RCRA | D-IV | CEPS, ASHM | Resource Conservation and Recovery Act - hazardous and chemical waste management |
Safety Committee | A-IV.C | ASHM | Can also include many other functions - chemical hygiene, biosafety, radsafety, etc. |
Training | A-III | ASHM | Training, in some form or fashion, and in some cases quite rigorous, is required for almost all the above programs. |
NOTE: This list is not all inclusive. Also, Manual 230 is being updated and is in its next-to-final format. The above citations are for the current Manual and will not be the same in the new manual.
