Focused Inspection vs. Comprehensive Inspection

Did you know that if you put a comprehensive safety program in place you may be entitled to a "Focus 4 Inspection" rather than a "Comprehensive Inspection" when OSHA shows up at your construction job site?

While I was performing a lot of construction job site consultations, most contractors were not aware of it. It could really help you limit your potential fines. But, more importantly, it helps you to identify and eliminate hazards and create a safer worksite for your employees.

Safety and Health Management Program

In order to comply with the General Safety & Health Provisions outlined, it is necessary to establish a formal, written safety and health program. In addition, by developing and implementing a written safety and health program our company will qualify for a “Focused Inspection” rather than a “Comprehensive Inspection” should we receive a compliance visit from OSHA. 

Under previous OSHA policy all construction inspections were comprehensive in scope, addressing all areas of the workplace and by inference all classes of hazards. This guidance may have caused compliance officers to spend too much time and effort on a few projects looking for all violations and, thus, too little time overall on many projects inspecting for hazards which are most likely to cause fatalities and serious injuries to workers. Previously, a contractor was likely to be cited for hazards that were unrelated to the four leading causes of death that make up 90% of all construction fatalities (falls from elevations — 33%; struck by — 22%; caught in/between — 18%; electrical shock — 17%). Although these other conditions are important, the time and resources spent to pursue them on a few projects can be better spent pursuing conditions on many projects related to the four hazard areas most likely to cause fatalities or serious injuries. The goal of OSHA's construction inspections is to make a difference in the safety and health of employees at the worksite. 

To accomplish this, the CSHO's time will be more effectively spent inspecting the most hazardous workplace conditions. The CSHO shall conduct comprehensive, resource intensive inspections only on those projects where there is inadequate contractor commitment to safety and health. It is this group of employers that will receive our full attention. 

Read more on OSHA's website:

Guidance to Compliance Officers for Focused Inspections in the Construction Industry.

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Author: Deborah Grow, Safety Consultant

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OSHA SST List is back!

Site-Specific Targeting 2016 (SST-16) Program

In the good old days, OSHA inspections primarily occurred for one of four reasons:

• Employee Complaints
• Severe Accidents
• Observed OSHA Violations (e.g.: inspector observes an issue on a construction site)
• Random Inspection (a statistical likelihood once every 200 years)

The change from a “reactive” to a “proactive” philosophy represented a significant and important departure from the way they have historically conducted business. To identify the country’s most dangerous companies to work for, OSHA formed the Site-Specific Targeting (SST) Inspection Program. Each year they produce a SST list of employers, Each year they produce a SST list of employers, commonly referred to as the “Hit List.” 

OSHA has not published such a list since 2013. But, they just published the 2018 list and it did not get much coverage and is hard to find. As a matter of fact, it is almost impossible to find it or any notice about it all.

The link below provides and automatic download of the Directive 18-01 (CPL 02)

OSHA launches program to target high injury and illness rates

Site-Specific Targeting program will target high-injury-rate companies for inspection.

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) is initiating the Site-Specific Targeting 2016 (SST-16) Program using injury and illness information electronically submitted by employers for calendar year (CY) 2016. The program will target high injury rate establishments in both the manufacturing and non-manufacturing sectors for inspection.

Under this program, the agency will perform inspections of employers the agency believes should have provided 300A data, but did not for the CY 2016 injury and illness data collection. For CY 2016, OSHA required employers to electronically submit Form 300A data by December 15, 2017. The CY 2017 deadline was July 1, 2018; however, employers may still provide this information to the database.

Going forward, establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in specific industries with historically high rates of occupational injuries and illnesses will be required to provide this information each year by March 2.

OSHA’s On-site Consultation Program offers employers with up to 250 workers with free, confidential safety and health advice on complying with OSHA standards, and establishing and improving safety and health programs.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance.

For more information, visit www.osha.gov.

Download the OSHA Directive 

Author: Deborah Grow, Safety Consultant

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2018 Top 10 OSHA Citations announced

From the NSC Congress & Expo in Houston as published in Safety & Health Magazine

Fall Protection is OSHA’s most frequently cited standard for the eighth consecutive year, the agency and Safety+Health announced Tuesday at the 2018 National Safety Council Congress & Expo.

Patrick Kapust, deputy director of OSHA’s Directorate of Enforcement Programs, presented preliminary data for OSHA’s Top 10 most-cited violations for fiscal year 2018, which ended Sept. 30. Kevin Druley, associate editor for S+H, moderated the session.

The top five violations remained unchanged for the fourth straight year, with Hazard Communication, Scaffolding, Respiratory Protection and Lockout/Tagout following Fall Protection, respectively.

Eye and Face Protection emerged as a newcomer, ranking 10th.

“The Top 10 represents the most frequently cited standards, and they are a good place to start for the employer in identifying hazards in their own workplace,” Kapust said during the presentation.

The lists haven't changed much over the years.  Fall Protection still at the top of the list

Wouldn't ya think by now companies would pay attention?  It's not that hard to train employees and provide adequate fall protection.  There are so many options available now to employers.  What's the problem?

Author: Deborah Grow, Safety Consultant

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3 Phase Safety Action Plan

Having worked with numerous companies to implement an effective Safety & Health Management System, I'd like for you to consider the 3 Phase Safety Plan I developed to achieve success. The first phase includes improving employee and supervisor participation while at the same time increasing the hazard inspections so we can find and fix hazards before someone gets hurt

Utilizing OSHA’s plan, first, jot down what you already have in place and what you would need to develop.  It can be hard to figure out where to start, if you don't already have a lot in place.  So, I'd like to suggest that you start with your Vision, and then use my 3 Phase Safety Plan scorecards to monitor your progress.   

Remember the Plan-Do-Check-Act steps as you go

What is your vision or mission?

Our vision for safety and health is to create a safe workplace by reducing hazards which will reduce our accidents

In order to reach this vision we will implement the following long term safety goals using a partnership approach with management and employees

1.    We need to improve employee, supervisor, and management involvement and visibility

2.    We need to establish a baseline (by conducting a gap analysis of inspections, hazards, close call, and accident statistics) for what we plan to measure so we can establish a recognition program for those employees who step up and go above our expectations

3.    We strive to achieve ZERO accidents, but we'll absolutely expect to reduce our accidents by X % each year

4.    We need to conduct inspections for physical hazards, fix the hazards, and train employees about the hazards we found so they can help to prevent them from reoccurring

5.    We strive to identify hazards so they can be fixed so employees do not get injured.  So, we absolutely expect X inspections to be conducted

6.    We need to conduct observations for unsafe behaviors, motivate employees to change their behaviors, and train all employees about safe vs. unsafe behaviors so they can help us prevent them from re-occurring

7.    We strive to identify unsafe acts so they can be turned into safe acts so employees do not get injured.  So, we absolutely expect X behavior observations to be conducted

By Deborah Grow, Safety Consultant

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Safety Education for Employees

The Solution Is Obvious

 

- OSHA Act

Provide a safe and healthful workplace Free of recognized hazards

Then shouldn't we be educating employees about the OSHA rules, the hazards, looking for and correcting hazards? Shouldn't we want employees to bring hazards to our Attention so we can fix them before someone gets hurt? Shouldn't we want employees to report more close call or near miss? Don't we want to find the problems so we can fix them before someone gets seriously hurt? Shouldn't this be a Goal you want to continue to improve?

A primary goal of any safety action is to remove, reduce, or otherwise manage hazards. It’s obvious then that the first step must be to recognize the hazard!  While it is extremely important to identify hazards in the planning stage, Hazards are not static, they change over time as environmental, equipment, human, and management factors change! Hazard Recognition is a never ending necessity at all stages and levels in each and every task!

Increase workplace inspections to identify new or previously missed hazards, Find and fix more hazards, Train employees about hazards and JSA procedures (more than once so they remember! Find a positive way to increase reporting of near miss or close calls and investigate a near miss just as you would an OSHA recordable or lost time (in a timely manner) and then recheck that JSA you wrote to perform that task. If that JSA is well written, employees have been well trained on the tasks, hazards, and controls to prevent accidents, and you have a close call or near miss........then you missed something and need to address it.

• How many inspections you do and how many hazards are being found and how long it takes to get hazards corrected are leading indicators of how effective your inspection and hazard reporting programs are
• How many training sessions and how well the employees retain the information are leading indicators of how effective your training program is. If your hazard reporting is low, but you still have close call or accidents, then perhaps you should focus training on hazards or unsafe acts
• How many hazards are found and corrected in a timely manner are leading indicators of how effective your safety program really is

Safety Goals

• To Increase the number of inspections for hazards by X % over the previous year
• To increase the number of hazard reports received by X% over the previous year
• To increase the number of close call or near miss reports received by X% over the previous year
• To investigate all hazardous events within X number of days of the occurrence

What Gets Measured Gets Done

What Gets Celebrated Gets Done Well

Author: Deborah Grow, Safety Consultant

Need help with Safety? Let’s schedule a free consultation!

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