OSHA Compliance: Ensuring Laboratory & Manufacturing Safety at Your Worksite
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Are you prepared for your next OSHA audit? Ensuring OSHA compliance requires a complete understanding of the OSHA requirements and a complete assessment of your current workplace. In this session, Rick will walk you through the key steps to building a compliant EHS program at your worksite and the key performance indicators needed to measure EHS progress.
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OSHA Compliance: Ensuring Laboratory & Manufacturing Safety at Your Worksite
- 1. OSHA Compliance: Ensuring Laboratory & Manufacturing Safety at Your Worksite Rick Foote, Triumvirate Environmental
- 2. OSHA Has Been Busy • OSHA Conducted 92,000 inspections • There were over 188,000 violations cited • There was approximately $240 million in penalties 2
- 3. Top 10 Violations 1. Duty to Provide Fall Protection (7,270 violations) 2. Hazard Communication (4,552 violations) 3. Scaffolding (3,336 violations) 4. Respiratory Protection (3,118 violations) 5. Lockout/Tagout (2,944 violations) 6. Ladders (2,812 violations) 7. Powered Industrial Trucks (2,294 violations) 8. Fall Protection (1,982 violations) 9. Machine Guarding (1,972 violations) 10. PPE (1,536 violations) 3
- 4. Are you ready for OSHA to knock at the door? 4
- 5. OSHA Inspections • Preparation is Key! 5
- 6. Form a Committee • EH&S • Facilities Dept. • Maintenance • Environmental Services • Clinical Lab • Researcher Admin. • Radiology • Pharmacy • Plant Operators 6
- 7. Organize Internal Resources • Preparedness Coordinating Committee • Facility Program Managers/Experts • Facility Inspector Escorts • Logistics and Planning • Roles & Responsibilities • Communications 7
- 8. Inspection Preparedness Coordinating Committee • Organizes and facilitates the Opening Conference • Works out schedule with the inspectors • Coordinates inspections with department/program managers • Conducts daily debriefings • Organizes and facilitates the Closing Conference 8
- 9. Facility Inspector Escorts • Introduces the inspector and convey seriousness of the interview. • Intercedes when leading questions are asked during an interview • Tactfully restates misunderstood questions to interviewee. • Doesn’t allow unqualified people to respond to questions 9
- 10. OSHA Inspections - Tips • Be Prepared! ▪ Maintain up-to-date plans and records ▪ Know where documents are; be able to produce them in a timely manner ▪ Have a Preparedness Plan • Records and Documentation Review ▪ Assemble materials requested by OSHA ▪ Identify conference room (do not use offices) for records review ▪ Offer only requested documents for specific locations ▪ Make duplicate copies of records that they copy 10
- 12. Inspections: Logistics and Planning • Internal Notification (“The British are Coming”) • Enacting the Preparedness Plan ▪ Opening Conference ▪ Coordinating a schedule with OSHA ▪ Debriefings with parties inspected 12
- 13. Opening Conference • State that the group has been assembled to help facilitate the inspectors’ review & provide an open communication channel with key facility officials • Outline positive working relationship with OSHA inspectors • Discuss how important compliance is to your facility • Who in upper management is involved and how often your department meets with them • Obtain an understanding of inspection scope 13
- 14. Guidelines: Site Inspection • Identify nature and scope of inspection • Accompany each inspector at all times • Cooperate, but do not offer information not requested • Duplicate all records copied • Take good notes, photographs, split samples • Monitor employee interviews • Conduct an exit interview for each area to get an idea of what they found 14
- 15. Facility Escort Guidelines • Restate unclear answers from the interviewee to the OSHA inspector • Stay by the inspectors side • Take notes • During and shortly after the interview • Of issues that the inspector notes during the inspection • Of questions that could not be answered 15
- 16. Taking care of business • Fixing Potential Violations ▪ As issues are found ▪ Prior to OSHA entry ▪ Before OSHA finishes for the day • Behind the Scenes During the Inspection ▪ OSHA Location during the day ▪ Fielding questions 16
- 17. Closing Conference • Consider having VP level representative and attorney present • Present documentation of correction actions taken during the inspection • Have answers to questions that couldn’t be answered in the field 17
- 18. More Guidelines • Take notes • Don’t attempt to deal with hypothetical situations • “Fix” simple deficiencies along the way • Make a copy of anything given to the inspectors • Seek approval for all photos requested by the inspectors; take duplicate photos • Likewise, take duplicate samples 18
- 19. Guidelines Continued… • Don’t offer an opinion or agree/disagree with the inspectors • Do talk about sports, music, general topics • Don’t be their “buddy” or confidant • Don’t sign anything • Keep them from harm’s way (no confined space entry or near high hazard areas) 19
- 20. Guidelines Continued… • Don’t offer information unless specifically asked • Don’t argue with the inspectors • Don’t complain about the regulations • Don’t be pushed into giving an answer if you don’t know…say that you don’t know • Don’t be evasive. Answer directly and succinctly • Don’t lie to the inspectors or misrepresent what really happens in your area • Don’t engage in speculation 20
- 22. OSHA Regulations Requiring Training • 1910.38 - Emergency Action Plans • 1910.39 - Fire Prevention Plans • 1910.66 - Powered Platforms for Building Maintenance • 1910.95 – Occupational Noise Exposure • 1910.106 – Flammable and Combustible Liquids • 1910.109 - Explosive and Blasting Agents • 1910.110 - Storage and Handling of Liquefied Petroleum Gases • 1910.111 - Storage and Handling of Anhydrous Ammonia • 1910.119 - Process Safety Management of Highly Hazardous Chemicals • 1910.120 - Hazardous Waste Operations and Emergency Response 22
- 23. OSHA Regulations Requiring Training • 1910.177 - Servicing of Multi-Piece and Single-Piece Rim Wheels • 1910.178 – Powered Industrial Trucks (forklift operator training) • 1910.179 – Overhead and Gantry Cranes • 1910.180 – Crawler, Locomotives and Truck Cranes • 1910.181 – Derricks (material handling) • 1910.183 – Helicopters (for material handling) • 1910.184 – Slings (material handling) • 1910.217 – Mechanical Power Presses • 1910.218 – Forging Machines • 1910.252 – 1910.255 – Welding, Cutting and Brazing 23
- 24. OSHA Regulations Requiring Training • 1910.261 - Pulp, Paper, and Paperboard Mills • 1910.262 – Textiles • 1910.264 - Laundry Machinery and Operations • 1910.265 – Sawmills • 1910.266 – Logging Operations • 1910.268 – Telecommunications • 1910.269 - Electric Power Generation, Transmission, and Distribution • 1910.272 – Grain Handling Facilities • 1910.332 – 1910.333 – Electrical Safety Related Work Practices • 1910.410 – 1910.440 - Commercial Diving Operations 24
- 25. OSHA Regulations Requiring Training • 1910.1000 – Toxic and Hazardous Substances • 1910.1001 – Asbestos • 1910.1003 – 1910.1016 – Thirteen Carcinogens • 1910.1017 – Vinyl Chloride • 1910.1018 – Inorganic Arsenic • 1910.1020 - Access to Employee Exposure and Medical Records • 1910.1025 – Lead • 1910.1026 - Chromium (VI) • 1910.1027 – Cadmium • 1910.1028 – Benzene • 1910.1029 - Coke Oven Emissions • 1910.1030 – Bloodborne Pathogens • 1910.1043 – Cotton Dust 25
- 26. OSHA Regulations Requiring Training • 1910.1044 - 1,2-Dibromo-3-Chloropropane • 1910.1045 - Acrylonitrile (Vinyl Cyanide) • 1910.1047 - Ethylene Oxide • 1910.1048 – Formaldehyde • 1910.1050 – Methylenedianiline • 1910.1051 - 1,3-Butadiene • 1910.1052 - Methylene Chloride • 1910.1096 – Ionizing Radiation • 1910.1200 – Hazard Communication • 1910.1450 - Occupational Exposure to Hazardous Chemicals in Laboratories 26
- 27. Preparedness 27
- 28. Be Ready! 28 • Develop an OSHA compliance calendar • Ensure all of the required written plans are up to date • Develop a training matrix • Keep records organized and ready for inspection • Review the OSHA 300 Log • Conduct internal inspections • Involve employees to get their buy-in • Enforce programs such as personal protective equipment, safety devices, etc.
- 29. How Safe Are Your Lab Spaces? 29
- 30. Does your lab look like this? 30
- 31. Lab Inspections • Conduct regularly and non-regularly scheduled lab inspections • Ensure that you speak to personal in the area to ensure they understand the issues that have been identified • Conduct hands on training in the lab space 31
- 32. Manufacturing Safety • Do you conduct tool box talks? • When was the last time you did a compliance walk with a group of employees? • When was the last time you did training? • When was the last safety committee meeting? • Did you follow up on the notes from the meeting? 32
- 33. 33
- 34. Compliance Program • Stay Informed on regulatory changes • Conduct an Audit - Use the audit to determine applicability and gaps in programs • Be Prepared! - Have information readily available • Develop a compliance calendar 34
- 35. Measuring Success • Develop Key Performance Indicators • Train people and measure effectiveness • 3rd Party Reviews • ISO Certifications • Great Inspection Outcomes 35
- 36. Questions?