Yesterday, we highlighted the first 3 of 5 steps for handling the OSHA citation abatement process successfully. Today, we conclude with steps 4 and 5.
4. Verify. To verify abatement, you must provide OSHA with one or more of the following forms of abatement verification documentation:
- A photograph or video of the abated condition
- An invoice or sales receipt for equipment used to achieve abatement
- A report by a safety and health professional describing actions taken to abate the hazard or describing the results of analytical testing that substantiates abatement
- Documentation from the manufacturer that the item repaired (equipment, for instance) is within the manufacturer’s specifications
- A copy of a signed contract for goods and services (for example, an evaluation by a safety engineer)
- Records of training completed by employees if the citation is related to training requirements
- A copy of program documents if the citation is related to a missing or inadequate program (for instance a hazard communication or respiratory protection program)
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5. Tag. Any cited movable equipment, including rented equipment, must be tagged with a warning or a copy of the citation. When tagging movable equipment:
- Put a warning tag or a copy of the citation on the operating controls or cited components of the equipment immediately after the citation is received.
- Warn employees on the tag about the cited hazard, briefly describing the violation and telling them where to find the complete citation.
- You can only remove a tag after you have:
- Corrected the violation and submitted all required abatement verification documents to OSHA;
- Permanently removed the equipment from service;
- Received an order after a hearing contesting a citation that states the citation has be vacated; or
- Given up control of the equipment (for example, sold it and placed it under the control of the buyer or returned it to a rental company).
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