1. OCCUPATIONAL SAFETY INSPECTIONS: HOW TO REPRESENT YOUR CAMPUS DURING THE INSPECTION PROCESS University of Wisconsin System Office of Safety and Loss Prevention Version: July 2012

2. 2 Overview Version: July 2012 Training goal:  To prepare you to handle an occupational safety inspection at your campus Steps:  Review the rules for the safety inspection process  Explain the inspection visit  Post-inspection Regulatory Safety Inspections

3. 3 Version: July 2012 Supplementary Material  Checklist for DSPS Occupational Safety Inspections  Links to other information at: http://web.uwsa.edu/oslp/ehs/occupational-safety/misc-safety/enforcement/

4. 4 Rules for the safety inspection process Version: July 2012 Regulatory Safety Inspections

5. 5 Safety regulation on campus Version: July 2012  Public employee safety enforced by Wisconsin Department of Safety and Professional Services  Adopted most of OSHA regs  See also Statute, Administrative Code  Student employees covered while working Regulatory Safety Inspections

6. 6 Safety regulation on campus Version: July 2012 Regulatory Safety Inspections  Contractor employee safety: OSHA  Lead paint, asbestos: DHS, SPS, OSHA  Other agencies: DOT, EPA, DEA

7. 7 Dept. of Safety and Professional Services Version: July 2012 Regulatory Safety Inspections

8. 8 Advance notification Version: July 2012 Regulatory Safety Inspections  Inspections  Without advance notice

9. 9 Why does an inspection occur Version: July 2012 Regulatory Safety Inspections  Inspections are created by:  Complaint  DWD referral

10. 10 When/how should inspections occur? Version: July 2012 Regulatory Safety Inspections  Inspectors have statutory authority to:  Enter without delay and at reasonable times  Inspect and investigate the workplace: during regular working hours at other reasonable times  Campuses have the right to expect  Inspection conducted in reasonable manner, within reasonable limits

11. 11 Confidentiality Version: July 2012 Regulatory Safety Inspections  Names of employees filing a request for inspection can be kept confidential

12. 12 Participation in inspection Version: July 2012 Regulatory Safety Inspections  A campus management representative and a public employee representative must be allowed to participate in the inspection

13. 13 Notification Version: July 2012 Regulatory Safety Inspections  At the start of the inspection, the campus must notify representatives of any campus collective bargaining unit about the inspection

14. 14 Private questioning Version: July 2012 Regulatory Safety Inspections  Inspectors have statutory authority to “question privately any employee or employer”  Confidentiality vs. privacy  Confidentiality provides protection only of identity of complainant  Does not provide anonymity to employees questioned during inspection

15. Version: July 2012Regulatory Safety Inspections

16. 16 Other rules Version: July 2012  Reporting and recordkeeping  Injury and illness reporting; exposure and monitoring records; observation of monitoring  Employee notification of exposure  “Whistleblower” protection  For filing complaint  For testifying  For reasonably refusing to perform a task which represents a danger of serious injury or death Regulatory Safety Inspections

17. Posting requirements Version: July 2012Regulatory Safety Inspections 17

18. 18 The inspection Version: July 2012 Regulatory Safety Inspections

19. 19 Steps to take now Version: July 2012  Select 3 or more campus management representatives for inspection visits  Provide training and awareness of the process Regulatory Safety Inspections

20. 20 Previous enforcement activity Version: July 2012  Repeated areas of emphasis  Personal protective equipment (PPE)  Respiratory protection  Air contaminants  Hazard communication  Laboratory Standard  Asbestos management Regulatory Safety Inspections

21. Previous enforcement activity o Welding o Fume hoods o Chemical storage o Housekeeping o Confined spaces o Signage o Hearing conservation o Bloodborne pathogens o Eyewashes o Emergency response plans  Other areas of citation Version: July 2012Regulatory Safety Inspections 21

22. 22 Team communication Version: July 2012  Set up procedures for how to handle an enforcement action  Who in campus management needs to hear about it  What information gets shared  How to share information  Who is responsible for following the action through to the end Regulatory Safety Inspections

23. 23 Arrival of inspector Version: July 2012  Be polite, cordial, fair and firm  Campus management representative should verify the inspector’s credentials/ID  State of Wisconsin ID card DSPS on front, Safety & Buildings on back  Deputy ID card White with Dept logo and words “Deputy Identification” Back of card has statutory citations Regulatory Safety Inspections

24. 24 Opening conference Version: July 2012 Regulatory Safety Inspections  Ask for a brief opening conference  Reason for visit / intended scope  If complaint, ask for details of complaint  Notify campus bargaining unit reps of inspection  Determine the public employee rep on the inspection  Know your rights  That the inspection is reasonable  To be present for the inspection

25. 25 Opening conference Version: July 2012  Plan/propose inspection route  “Go-Kit” Regulatory Safety Inspections

26. 26 Where is that…? Version: July 2012  OSHA 300 logs  Chemical hygiene plan  Fume hood test records  HazCom program, MSDS records  Respiratory protection program  Hazard assessments for PPE use Regulatory Safety Inspections

27. 27 Walking around Version: July 2012  Use of camera  If inspector takes a picture, you take same picture  Notes  Find the right people  Be a boring minimalist  Admission of violation?  Immediate corrections Regulatory Safety Inspections

28. 28 Wrapping it up Version: July 2012  Closing conference  What did inspector determine?  What needs to be done? Regulatory Safety Inspections

29. 29 Post-inspection Version: July 2012 Regulatory Safety Inspections

30. 30 After the inspector departs Version: July 2012 Regulatory Safety Inspections Office of Safety and Loss Prevention University of Wisconsin System Administration Daniel Karamanski, Occupational Safety Manager (608) 262-4792 dkaramanski@uwsa.edu  Inform others involved in safety and management about inspection  Inform UW System  Formalize your notes

31. 31 What happens next? Version: July 2012  Workplace in compliance, or…  Issuance of orders  Comply with orders  Appeal: ‘Review by department’  Meetings, review of compliance plans, further inspection visits Regulatory Safety Inspections

32. 32 If you have questions… Version: July 2012 Contact the Office of Safety and Loss Prevention University of Wisconsin System Administration Daniel Karamanski, Occupational Safety Manager (608) 262-4792 dkaramanski@uwsa.edu Again, links to material related to this topic can be obtained at: http://www.uwsa.edu/oslp/safety/uwsres/Commerce/Commerce_safety_reg.htm Regulatory Safety Inspections