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Published byCaroline Wells Modified over 8 years ago
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The ABC’s of DOSH Inspections Holly Markee Approach Management Services 253-208-1671
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Resources, Rights, Respect Why does the department choose to inspect your workplace? Inspection process Best practices for Employers
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“Why Inspections Happen” Imminent Danger Fatality/Accident Complaints/Referrals Scheduled Inspection
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“Imminent Danger” “Reasonably expected” to cause death or serous physical harm
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Fatality or “Accident” Accident: injuries requiring hospitalization at least overnight of one or more employees.
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Notice of alleged hazard or violation of safety & health standard Complaint – made by an employee
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Notice of alleged hazard or violation of safety & health standard Complaint – made by an employee Referral – by anyone else
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“Scheduled Inspections” High hazard/high claims industries such as construction and logging Industries with recent history of increased Individual companies with high injury/claims Individual companies that have not had an inspection recently
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“Pre-Inspection” Look at previous injuries and causes Look at all previous inspection history Look at your companies Experience Factor Any consultation history-POSITIVE
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Initial Stages Approach to your office/jobsite
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Initial Stages Approach to your office Introduction-Show credentials “Permission to Inspect”
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Initial Stages Approach to your office Introduction Opening Conference
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Making a Good Impression Have written programs readily available Give them a prepared “visitor safety briefing” Attitude Professional Courteous
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Walk-Around Look at equipment, machinery Observe processes; employee activities Interview employees Determine if hazards exist Have the Describe how
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H.E.C.K Hazard: Is there a potential for injury? Exposure: Have employees been exposed to the hazard? Or will likely be? Code: Is there a safety code regarding the hazard? Knowledge: Knowledge of the safety hazard by the employer.
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Observe Activities/Processes How do people typically do their jobs? What’s the flow of goods/services?
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“Look At Equipment/Machinery” Is it set up per manufacturer’s specs? Are there hazards? – “Guarding on machinery” – “Inspections completed and documented?” – “Electrical Hazards” Is there “Exposure”?
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“Look At Equipment/Machinery” Is it set up per manufacturer’s specs? Are there hazards? – “Guarding on machinery” – “Inspections completed and documented?” – “Interlocks Switches Disconnected” Is there “Exposure”?
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Fall Protection
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Hazard Assessment Welding Operation Proper Personal Protective Equipment? Welding Screens? Hand held grinders-Guards Is Respiratory Protection Required?
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Interview Employees Why Walk-Around Pay Discrimination How
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Interviewing Can they describe their safety training? How were they trained to do their particular jobs safely? Can they describe safety meetings? How would they report a hazard?
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Example: Forklifts Is there a training program? Have employees had training? Written test and operational? Re-training for near misses?
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Example: Hazardous Chemicals Is there a hazardous communication plan in writing. Is there an MSDS/SDS manual? Have the employees been trained? Is the training documented?
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Reviewing Documents - APP What does “outlined in writing” mean? Does APP address the actual hazards in the workplace? Is it “effective in practice”?
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Safety Committee/Safety Meetings Is there documentation that a safety committee has been established? Are their meetings documented? Have employee safety meetings been held? Are the meetings documented?
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Employee Records New employee orientation Training for the job Specialized training: equipment or processes Medical records –Respirator fit testing –Audiometer testing
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Criminal/Willful The employer violated a WISHA standard The violation was willful in nature The violation of the standard caused the death of the employee
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Willful A willful violation exists when evidence shows either an intentional violation of WISHA or plain indifference to its requirements. 3X Repeat Serious is always evaluated as potential Willful
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Serious Violations A substantial probability that death or serious physical harm could result from a condition which exists.
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General Violations Hazard will not cause death or serious physical harm to employee, but does have a direct relationship to their safety and health.
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Grouping of Violations When one action corrects two hazards When two general violations combined create a substantial probability of serious physical harm When there are multiple violations of posting or recordkeeping requirements that involve the same document
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Repeat Violations Repeat violations exist whenever the previous violation involves a substantially similar hazard. Previous citation must be a final order Previous citation must be within three years
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Failure to Abate A violation from an inspection that has not been corrected as required.
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Program Violations APP- Must describe total safety program Hazard Communication program Confined Space Program Hearing Conservation Program
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De minimis Violations Employer complies with clear intent of standard
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Penalties Good Faith Size History
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Closing Conference Recap “observed hazards” –Item-by-item review –Employer input/explanation –How to fix hazards
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Employers Can Make a Difference Find and fix before the inspector shows up – Get active employee involvement Have all required programs – In place developed by you with employees – In use by your employees Be prepared -have a process in place Participate in the inspection as a way to avoid injuries & expenses
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