OSHA Consultation Program Annette Olesen CIH, CET Cynthia Mellen CSP
Occupational Safety and Health Act of 1970 Enforcement Consultation Each State and US Territory must provide safety and health consultation services Funded by Federal OSHA at 90% IUP and PA DOL at 10% 1 of 8 university based programs Pennsylvania is the 2 nd largest in U.S.
To assist PA employers with: complying with OSHA standards saving workers lives and their livelihoods preventing needless occupational injuries, illnesses and disabilities minimizing property damage and costs avoiding OSHA penalties, fines and criminal prosecutions reducing workers compensation costs attaining and sustaining economic viability
Program Director: Sam Gualardo Safety and Health Consultants (10) All are Board Certified Professionals CSPs or CIHs Strategically located throughout PA Administrative Staff (2)
Small-and medium-sized businesses 250 employees at a single site or 500 corporate wide Priority assistance given to: employers in high-hazard industries involved in hazardous operations Large business requests honored as well…but limited scope
Onsite at YOUR company: Physical hazard evaluations Industrial hygiene exposure monitoring Regulatory required program assessment and development assistance Regulatory required training assessment and delivery Post OSHA inspection compliance assistance Safety and health management program development assistance… leading to OSHA inspection deferral (Pre-SHARP) SHARP
Offsite Daily telephone E-mail assistance Interventions Presentations and seminars
Requests received and assigned to consultants Onsite visit Opening conference Review of regulatory program Training Recordkeeping requirements Walkthrough of facility Physical hazards evaluation Closing conference
Report generated with Specific hazards Correction recommendations Completion timelines
Different than OSHA enforcement No Citations issued No Penalties imposed The “catch” Employer must agree to correct t any “ serious ” hazards identified (within agreed upon time period) “ imminent danger ” identified (immediately) Must refer to OSHA Enforcement if employer fails to provide documentation of hazard correction…very rare !
Must maintain total employer confidentiality Cannot divulge any information to: OSHA Enforcement Lawyers pursuing liability cases Protected from subpoena's A request fo for Consulta ltati tion on Services s wi will not trigger r an OSHA inspection… It may prevent one and will defi finitely y reduce the impact t if o f one occurs! s!
Must have: An exemplary safety and health management system. OSHA rates better than their industry average Exempt from OSHA programmed inspections… for up to 3 years
Be a single, fixed worksite Have at least a one (1) year of operating history Exhibit a reasonable promise of achieving agreed- upon milestones and time frames for SHARP participation Priority for Pre-SHARP/SHARP participation will be given to employers with 250 or less employees onsite.
CANNOT NOT have an incentive program that would: ◦ Discourage Reporting Injury and illness: Forms of recognition to a unit that has the greatest reduction in incidence rates awarding paid time off or other benefits Rewarding workers with a pizza party for achieving an injury/ rate reduction goal or maintaining an injury and illness free worksite for a period of time ◦ Discourage Workplace involvement
Acceptable Incentives are those that PROMOTE and ENCOURAGE: ◦ safety awareness ◦ Injury and illness reporting ◦ Worker involvement ◦ Positive incentive program encourages or rewards workers for ◦ Reporting injuries, illnesses, near-misses or hazards ◦ Involvement in Injury and Illness prevention programs
Receive a full service safety and health consultation visit, and a comprehensive review of their safety and health management system. Receive a score of at least “two” on all fifty basic attributes of the Safety and Health Program Assessment Worksheet (OSHA Form 33). Correct all hazards identified by the consultants: imminent danger serious other-than-serious regulatory
Agree to notify the program director and request a subsequent on-site consultation visit when ◦ changes in working conditions or ◦ work processes occur that may introduce new hazards into the workplace. Submit a request for Pre-SHARP or SHARP participation and an Action Plan or Achievement Plan to the program director. Currently 54 54 Pennsylvania companies in SHARP
Are not able to meet all the SHARP eligibility criteria Are committed to working toward full SHARP approval Can meet all SHARP requirements during the deferral period May be recommended for an inspection deferral… up to 18 months Currently 4 4 Pennsylvania Companies in Pre-SHARP
Safety and Health Assessment Worksheet
Operational Managerial Cultural
Seven Categories: 1. Hazard Anticipation & Detection 2. Hazard Prevention & Control 3. Planning and Evaluation 4. Administration and Supervision 5. Safety and Health Training 6. Management Leadership 7. Employee Participation
0=No 1=No Needs major improvement; 2=Yes Needs minor improvement; 3=Yes NA= Not Applicable; NE= Not Evaluated; *=Stretch items Attribute of Excellence
Focus on workplace hazards
Concerns workplace hazards ◦ Hazard Anticipation & Detection Attributes 1-10 ◦ Hazard Prevention & Control Attributes 11-19
Legend: 0 = No; 1 = No, Needs major improvement; 2 = Yes, Needs minor improvement; 3 = Yes; NA = Not Applicable; NE = Not Evaluated * = Stretch Items Attribute of Excellence Detection HAZARD ANTICIPATION AND DETECTION 0 1 2 3 NA NE 1. A comprehensive, baseline hazard survey has been conducted within the past five (5) years. 2. Effective safety and health self-inspections are performed regularly. 3. Effective surveillance of established hazard controls is conducted. 4. An effective hazard reporting system exists. 5. Change analysis is performed whenever a change in facilities, equipment, materials, or processes occurs. 6. Accidents are investigated for root causes. 7. Material Safety Data Sheets are used to reveal potential hazards associated with chemical products in the workplace. 8. Effective job hazard analysis is performed. 9. Expert hazard analysis is performed. 10. *Incidents are investigated for root causes.
A comprehensive baseline hazard survey has been conducted in the past five years Effective safety and health inspections are performed regularly Effective surveillance of established hazard controls is conducted
An effective hazard reporting system exists Change analysis is performed when a change in: ◦ facilities equipment, ◦ materials, or ◦ processes occurs
Accidents are investigated for root causes SDSs are used to reveal potential hazards Effective Job Hazard Analysis is performed Expert Hazard Analysis Performed *Incidents are investigated for root causes
Legend: 0 = No; 1 = No, Needs major improvement; 2 = Yes, Needs minor improvement; 3 = Yes; NA = Not Applicable; NE = Not Evaluated * = Stretch Items Attribute of Excellence Detection HAZARD PREVENTION AND CONTROL 0 1 2 3 NA NE 11. Feasible engineering controls are in place. 12. Effective safety and health rules and work practices are in place. 13. Applicable OSHA-mandated programs are effectively in place. 14. Personal protective equipment is effectively used. 15. Housekeeping is properly maintained. 16. The organization is properly prepared for emergency situations. 17. The organization has an effective plan for providing competent emergency medical care to employees and others present at the site. 18. *Effective preventive maintenance is performed. 19. An effective procedure for tracking hazard correction is in place.
Feasible engineering controls Effective S&H rules and work practices Applicable OSHA mandated programs PPE effective Housekeeping Prepared for emergencies Competent medical care *Effective PM performed Effective tracking of hazard corrections
Focus on effect of traditional managerial functions
◦ Planning & Evaluation Attributes 20-25 ◦ Administration & Supervision Attributes 26-33 ◦ Safety & Health Training Attributes 34-39
Legend: 0 = No; 1 = No, Needs major improvement; 2 = Yes, Needs minor improvement; 3 = Yes; NA = Not Applicable; NE = Not Evaluated * = Stretch Items Attribute of Excellence Detection PLANNING AND EVALUATION 0 1 2 3 NA NE 20. Workplace injury/illness data are effectively analyzed. 21. Hazard incidence data are effectively analyzed. 22. A safety and health goal and supporting objectives exist. 23. An action plan designed to accomplish the organizations safety and health objectives is in place. 24. A review of in-place OSHA-mandated programs is conducted at least annually. 25. *A review of the overall safety and health management system is conducted at least annually.
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