By: Monica Meyer
OSHA enforcement has changed over the years and its bite now measures up to its bark. As of August 2016, fines for violations have increased by almost 60% from previous established maximums. If OSHA shows up at your door, it is not likely going to be a friendly visit. Your management team should be prepared for an inspection that will likely focus on worker complaints; however, once a compliance officer is in your facility, agency directives require the inspection to include the entire workplace. As the number of small violations add up, the deeper the compliance officer will look to find deficiencies. Are you following OSHA’s recent enforcement goals and priorities? Are you aware of new OSHA National and Special Emphasis programs? Do you know where health and safety (H&S) violations may exist within your company? Did you know that OSHA can fine your company on a per-employee basis? What processes do you have in place to be prepared for that unannounced visit from an OSHA compliance inspector?
EHS Support has a long track record of assisting companies across various industries to meet their compliance goals, prepare them for OSHA inspections, and appeal OSHA inspection findings. We can remove the uncertainty surrounding OSHA’s larger proposed fines, their recent history of classifying more fines as willful or repeat violations, levying fines per employee rather than one fine covers all, and the potential for jail time for managers.
At EHS Support, our audit process is a fact-finding exercise, not a fault-finding exercise. Let a seasoned health and safety compliance auditor walk you through our mock-OSHA audit process and clearly define your compliance short-comings as well as your good practices. But we don’t stop there! We will provide meaningful corrective actions that can be implemented by your staff. Also, compliance with governmental safety standards should be considered a minimum baseline requirement. Our audit process is more comprehensive than a simple inspection and includes an analysis of safety management systems, training needs, and recommendations for long-term improvement.
Progressive companies that truly care about the safety and health of their employees can see beyond the governmental requirements and shift the emphasis from compliance to risk. Are the risks acceptable and as low as reasonably practicable at the level of compliance? We can help define that for you.
By taking a deeper dive into Human Resources (HR), risk potential, frequency and severity of incidents, culture clashes, workers’ compensation insurance evaluation dates and experience modifiers (MOD rates/EMR), and industry best practices, we can offer solutions to positively impact your H&S program, culture, your bottom line, and most importantly, the safety of your most important asset – your employees.
The EHS Support Mock-OSHA Audit Process
Before ever setting foot in your facility, we meet with senior management to better understand your company, operations, culture, and H&S items of concern, and to plan the audit. We forward a request list of items that we will need to review prior to the site visit or during the first day of the site visit.
Opening Conference – The site visit will begin with an opening conference that should include key personnel responsible for the implementation of your H&S programs. We will discuss the scope of the inspection, walkaround procedures, employee representation, and employee interviews.
Desktop Review – Following the opening conference, the auditor will review all requested information including, but not limited to:
- OSHA logs
- H&S Management Systems
- H&S policies and procedures
- Training documentation
- Injury and illness reports
- Injury and illness investigation
- Company handbook
- 3rd party inspections
- Internal inspections
- Job hazard/safety analyses
- Personal protective equipment
- Safety data sheets
- New hire on-boarding process
- Industrial hygiene risk
- Assessments, evaluations, and data
- Behavior based safety program
- Loss runs from WC carrier
- MOD rate
- Substance abuse policy
Wall-to-Wall Inspection – Following the desktop review and the opening conference, the auditor and company representative(s) will walk through all areas of the workplace inspecting for items of noncompliance and hazards that could lead to employee injury and/or illness. This also provides insight as to how well the established H&S program is executed by personnel. During the walk through, our auditors will speak with employees about the H&S program to evaluate how effective training programs and other H&S communication are throughout the organizational structure.
Closing Conference – Following the wall-to-wall inspection, the auditor will conduct a closing conference with the employer and employee representatives to discuss the findings of noncompliance, potential findings of noncompliance, opportunities for improvement, and best practices.
Audit Report – The auditor will provide the company a detailed, easy-to-understand, customized report of the desktop review and inspection process. The report includes a spreadsheet describing the findings with federal and/or state regulation citations, opportunities for improvement (i.e., best management practices), actionable corrective measures to address deficiencies, and prioritization of risk and assignment of responsibility for implementation of the corrective measures. The report can then be used as a tool to track completion of corrective actions and improve your performance.
We also work with attorneys, if necessary, to perform this work at their direction to maintain attorney-client privilege protections.
OSHA Inspectors focus on 5 areas:
- Imminent Danger
- Fatalities and Catastrophes (resulting in hospitalization of 3 or more employees)
- Employee Complaints/Referrals
- Programmed High-Hazard Inspections
- Follow-ups to Previous Inspections
The best way to prepare for a potential or scheduled OSHA inspection is by contacting EHS Support for your mock-OSHA audit.
Experience + Expertise = Results
Contact Monica Meyer, our H&S Service Line Leader, for more information on the advantages of an EHS Support Mock-OSHA Audit.