News and Updates
Category: OSHA Inspections
OSHA's Aggressive Stance Continues
Things aren't slowing down at OSHA. If you feel like they've been mentioned in the news a lot lately, that's because they're keeping very busy. Workplace safety enforcement has added significant manpower and has been much more active than in previous years. Inspections have increased in number, as well as in breadth and depth, which is why it’s a great time to give your company a safety tune-up. There have been plenty of other regulatory distractions for management teams in 2023, which may have led to a reduction in attention to detail with required safety compliance programs. Pair that with the current OSHA administrator's aggressive background as the chief of Cal-OSHA, and your company should have a renewed desire to review OSHA compliance matters. This should include all of your written programs, as well as sub-elements under those programs. When is the last time you updated your health & safety written programs? When is the last time you checked to ensure all of your training is up to date and documented? When is the last time you completed a safety walk-through of your facility, with corrective action taken for any identified discrepancies? What are your compliance weaknesses? (Maybe you're not even sure) What are the underlying safety deficiencies contributing to your workplace injuries, leaving you vulnerable to OSHA penalties, and what are you doing to correct those issues? These a
OSHA Renews Focus on Healthcare Facility COVID Inspections
There’s certainly been no shortage of OSHA news recently, and their most recent push is aimed at the healthcare industry. From March 9, 2022 through June 9, 2022, OSHA will begin a focused, short-term inspection initiative directed at both hospitals and skilled nursing facilities that treat or handle COVID-19 patients. The goal is to mitigate the spread of SARS-CoV-2 and all of its variants, and ensure the overall health and safety of healthcare workers who are at a higher risk of being exposed to the virus in the workplace. The initiative will supplement OSHA’s existing targeted enforcement under the National Emphasis Program (NEP) for COVID-19. OSHA will use these partial-scope inspections to gauge employer compliance efforts as well as readiness for future COVID surges. These specific inspections will also make up 15% of OSHA’s inspections in each region during the three-month period. If your business falls under the following NAICS codes: 622110 General Medical and Surgical Hospitals (NCCI Codes 8833, 9040) 622210 Psychiatric and Substance Abuse Hospitals (NCCI Codes 8833, 9040) 623110 Nursing Care Facilities/Skilled Nursing Facilities (NCCI Codes 8824, 8826) 623312 Assisted Living Facilities for the Elderly (NCCI Codes 8824, 8826) And also meets any of these criteria: Follow-up inspection of any prior inspection where a COVID-19-related citation or hazard alert letter (HAL) was issued; Follow-up or monitoring inspections
OSHA Site Specific Targeting (SST)
The Site-Specific Targeting (SST) plan is OSHA’s main site-specific programmed inspection initiative for non-construction workplaces that have 20 or more employees. OSHA will generate inspection lists based on elevated Days Away, Restricted, or Transferred (DART) rates for 2019, and sites with upward trending rates for the three-year range of 2017-2019. They will also identify a random sample of establishments that did not provide them the required 2017, 2018, and 2019 Form 300A data. To verify data accuracy and quality control, OSHA also intends to include a random sample of low-rate establishments from the 2019 data. 1. High-Rate Establishments The SST plan selects individual establishments for inspection based on 2019 Form 300A data. Since average DART rates vary widely among industries, OSHA will set one DART rate for manufacturing and a different DART rate for non-manufacturing as objective selection criteria. 2. Upward Trending Establishments OSHA will identify establishments with rates above their industry’s national average in 2017 that have continued to trend upward in both 2018 and 2019 and continue to remain above their industry’s national average. 3. Low-Rate Establishments To verify the reliability of the Form 300A data reported to OSHA, the agency will generate a random sample of establishments with low DART rates using the 2019
Be Prepared for OSHA’s Omnipresence
The advertisement on the front page of OSHA.gov says a lot: “OSHA is Hiring! Apply Now.” Workplace safety enforcement has added significant manpower and has been much more active than in previous years. Inspections have increased in number, as well as in breadth and depth, which is why it’s a great time to give your company a safety tune-up. There have been plenty of distractions in 2021, which may have led to a reduction in attention to detail with required compliance programs. Pair that with the new administration's aggressive OSHA stance, and your company should have a renewed desire to review their OSHA Compliance. This should include all of your written programs, as well as sub-elements under those programs. When is the last time you have updated your health and safety written programs? When is the last time you checked to ensure all of your training is up to date and documented? When is the last time you completed a safety walk-through of your facility, with corrective action taken for any identified discrepancies? What are your compliance weaknesses (or maybe you’re not even sure)? What are the underlying safety deficiencies contributing to your workplace injuries, leaving you vulnerable to OSHA penalties, and what are you doing to correct those issues? These are the types of questions that our Spooner Safety team can help you answer, and get you on the right track
Surprise, It's OSHA! Dos and Don'ts for Surprise Inspections
Under the new administration, we have already seen a significant difference in approaches compared to the previous ones. Here is a recent example: An employee gets his arm caught in a machine and is hospitalized. Historically, in addition to the standard 5 years of OSHA 300/300A - OSHA would be looking at the machine and requesting the Lock Out/Tag Out (LO/TO) program. Now when OSHA shows up, it may look more like this: They look at the machine, request LO/TO and their written HazCom GHS program, Employee Orientation (onboarding) program, all LO/TO training documentation for Authorized and Affected employees, PPE Hazard Assessments, work instruction/training on machine in question, and Forklift Training Documentation. Is all of this requested material directly related to the incident? Not exactly - but they're going to expect you to supply it, regardless. Having said that, Spooner is encouraging all of our clients to review their OSHA Compliance, which should include all your written programs, sub-elements under those programs, and your facility. If you think you have nothing to worry about, ask yourself this: Once OSHA is in our facility, could we supply all of that requested documentation? Speaking of having OSHA at the door, we get a lot questions (and panicked phone calls) on that subject. To help you navigate that anxiety-inducing situation, here are some basic steps to take if you receive a “surprise” vis
