The best way to avoid OSHA citations is to identify and correct safety and health problems before an inspector finds them.
In a BLR webinar titled "OSHA’s Top 10: How To Stay Off This Infamous List in 2012," Attorney Tiffani Hiudt Casey outlined four key actions you can take to prepare your organization, make it a safer place, and help to prevent citations in the event of an OSHA inspection:
- Implement an injury and illness prevention program
- Prepare for an OSHA inspection in advance
- Train your managers and employees about safety
- Conduct self-audits and reviews
Today, we’ll cover the first two actions, and then we’ll discuss training and self-audits in tomorrow’s Advisor.
Casey is an associate in the Atlanta law office of Fisher & Phillips. She advises employers on OSHA recordkeeping, hazard assessment and self-audits, corporate-wide safety compliance, maintaining effective safety training and safety management programs, disciplining unsafe employees, inspection preparedness, workplace violence prevention, and health and wellness initiatives.
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1. Injury and Illness Prevention Programs
Casey points out that DOL has started the P3 Initiative Program—plan, prevent, protect—which would require planning, implementing, evaluating and improving processes and activities. This is similar to conducting your own audits, but would go the further step of being systematic and required.
Additionally, OSHA is considering applying a standard that requires employers to have injury and illness prevention programs, which some states already have. It is currently at the "pre-rule" stage. If implemented, it would build on voluntary safety and health management program guidelines currently in existence.
What happens if you do have an OSHA inspection? How can you be prepared? Casey outlines some preparatory steps you can take:
- Make sure you have the OSHA poster up.
- Assign responsibilities for all aspects of an inspection. The minute an inspector walks in the door, he or she needs to be met by personnel prepared to deal with the situation.
- Training should be in place and documented.
- Ensure required records are complete, current, and available. Designate a person to be responsible for providing requested records.
- Have any equipment needed during the inspection ready to go (for example, cameras to record the inspection).
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- Review insurance and third-party audits and take action accordingly.
- Prevent complaint inspections by enlisting employee involvement and ideas. Encourage employees to address safety concerns immediately and internally.
- Conduct hazard assessment and abatement.
- Review of previous citations and ensure that all previous OSHA citations are corrected.
- Establish work rules designed to ensure safe work and to avoid OSHA violations, communicate the work rules to employees, and enforce the rules and practices when violations are discovered.
- Know which OSHA standards are applicable and be compliant with those standards.
- Ensure support staff such as receptionists, secretaries, guards, etc., are trained in how to react and know what to say when the government is at your door.
Log on tomorrow for the last two steps to prevent OSHA citations—training and self-audits.