OSHA Inspections: Speakingofpriorities

December 10, 2009

OSHA inspections don’t just ‘happen.’ They are the result of some initiating circumstance that makes them a priority. OSHA inspection priorities  follow the hazards faced by the public that OSHA is charged to protect. While no lapse is desireable in one’s safety planning and execution, the highest priority items for OSHA should also be your highest priority to eliminate.

How many imminent dangers can you find?

Imminent danger situations. Hazards that could cause death or serious physical harm receive the top priority. As they should. Compliance officers (OSHA INSPECTORS) will ask employers to correct these hazards immediately. If the hazard cannot be removed, then the employees that are exposed should be.  Imminent danger and serious physical harm should not be part of working  in precision manufacturing.

Fatalities and catastrophes.  My take on this is that a catastrophe is an incident that requires the hospitalization of three or more employees. We all know what a fatality is. You must report these to OSHA within 8 hours. You can expect the OSHA follow up right away.

Complaints. If someone alleges that a hazardous situation exists, you can bet the agency will treat it seriously.  More seriously, in fact than referrals from other agencies.

Referrals from other agencies, organizations, or media. While these are not an assured way to initiate an investigation by OSHA,  they are considered.

Follow-ups (abatement). Checks to assure that violations cited from prior inspections are a lower priority, but remain a class of inspections that you can expect. Best prevention- Don’t have prior violations.

Planned or programmed investigations. The current National Emphasis Program  (NEP) on Recordkeeping is an example of this. These have been typically targeted at specific high hazard industries or workplaces that have high rates of injury and illness.

Whenever my team brought a problem in to me I asked them three questions.

 “Was there a procedure?”

“Was it followed? “

“Was it effective?”

 They always knew what the fourth question would be- Why not?

Do you have a procedure or system to assure that no imminent danger situations exist in your shop?

 Do you have a system to assure that your people are instructed, trained, and their knowledge reviewed to assure they follow safe and best practices?

Are you leading by example and setting the highest standards for safety, just as you do for quality and service, in your shop?

You know what the next question is.