|Surviving an OSHA Inspection|
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.
Biological Safety **
Mike Kiley on the National Program Staff oversees program. Oriented toward lab design & practices.
(AIDS, Hepatitis B, etc.)
ASHMs tend to take the lead on this, in consultation with Mike Kiley
Comprehensive Environmental Response, Compensation, and Liability Act - Cleanup of contaminated sites
Object: Protect employees from chem exposures
Clean Water Act
Object: Notify communities and emergency responders of our chemical hazards
Confined Space Entry**
Build safety into your lab from ground up
Employee Assistance Program - Psychological help
Facilities self protection*
Most facilities use GSA generic FSP plan
Fuel Storage Tanks*
ASHM, CEPS, AOE
We must fix or replace leakers, and install appropriate spill and leak equipment on all
Helpful inspection information also contained in old (and outdated) ARS Manual 232.1
Object: Advise employees of chemicals and other hazards at their worksite
Chemical disposal, primarily
HazWaste Cleanup, HWC
HWC provides $ for cleanup of past environmental sins, with out-of-agency funds.
You name it, the ASHM does it
A revised ARS 404 self inspection form is in next-to-final draft
Life Safety Codes
From the Natl Fire Protection Assn fire codes
Object: Control energy during maintenance
Revised & updated manual soon to be issued
National Environmental Policy Act
AOE, ASHM, CEPS
NEPA - environmental assessments for construction & major research
Occupational Health Maintenance Program
The OHMP matrix from 1983's Manual 235.1 is still in effect...and not reproduced in Manual 230.0!
Personal protective equipment*
You must perform written risk assessments to determine the type of PPE your people need
Manual 230 not yet updated to include Pesticide Worker Protection Standard
In some Areas, the ASHM/CEPS assist, but in all cases, RSS has primary jurisdiction
Resource Conservation and Recovery Act - hazardous and chemical waste management
Can also include many other functions - chemical hygiene, biosafety, radsafety, etc.
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.