Enforcement and Inspection

4 Steps to Preventing OSHA Citations: Part II

Yesterday, we introduced the first two or four actions that can help prevent OSHA citations. Today, we conclude with the final two steps, training and self-audits.

Attorney Tiffani Hiudt Casey, who advises employers on OSHA recordkeeping, hazard assessment and self-audits, and corporate-wide safety compliance, among other key issues, emphasizes the importance of proper safety training and frequent self-audits for maintaining a safe and compliant workplace—one that can stand up to and pass an OSHA inspection without a hitch.

Training

Casey says that managers and employees alike need to be trained and held accountable for implementing training skills and information on the job.

Managers in particular need to be trained to set an example by following the safety rules. They should be able to identify hazards and evaluate employee safety performance.

Employees must have any required OSHA training, and, of course, need to be trained on your worksite rules as well. Don’t just assume employees know the rules. Make sure.

Workers also need to understand how to identify hazards and how to report safety problems. Casey says they must understand OSHA protections as well and know that they are not required to work in an unsafe environment.

When the rules and procedures you train on are not followed, says Casey, there need to be repercussions. Don’t be afraid to discipline when necessary. That sends a firm message that unsafe behavior will not be tolerated.


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Self-Audits

In addition to a good training program, Casey emphasizes the importance of conducting self-audits and safety reviews on a regular basis. This is the best way to anticipate problems and get them fixed before an OSHA inspector ever gets to your door.

Self-audits will help you identify and correct hazards, update safety programs, and analyze OSHA logs and other records for patterns that will help you identify and correct problem areas.

Casey urges her clients to watch out for these pitfalls when conducting self-audits:

  • Infrequent audits. Even if you have a self-audit program in place, it is easy to get complacent and not complete it frequently enough to have real impact.
  • Incomplete audits. It is also easy to only complete a partial audit instead of a full audit.
  • Not correcting hazards found. Casey notes, "Once you identify a hazard, you now have knowledge of it . . . there’s a piece of paper that OSHA’s going to hold up in court." So be sure get any problems uncovered in a self-audit are fixed. This shows you’re taking the matter as seriously as you would an external audit or OSHA inspection. If you can’t fix something immediately, steps need to be taken to ensure employee safety until the time it can be fixed (such as taking a machine out of service, for example). Assign responsibility for fixing the problem, and hold those designated accountable for successfully resolving the problem.
  • Failure to document. Be sure to document your audits and corrective actions taken. This documentation will help prove good faith compliance with OSHA regulations.

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  • A review of applicable OSHA standards
  • Safety management tips
  • Training requirements
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