Cal/OSHAConsultation Service On-Site Visits

Peter Scholz, MPH, CIHAssoc. Safety EngineerOakland Area Office

Cal/OSHAConsultation vs. Enforcement

• Confidential (very limited exceptions)

• No fines or citations• No cost • Agreeing to fix any hazards found – that is

not voluntary.

Example: Solar Panel Installation

• Fall Protection needed over 7.5 ft.• Ladders must be secured during use• No carrying material up ladders• Need Injury and Illness Prevention Program• Need Heat Stress Program• Fork lift operators need to be formally evaluated

Example: Soup Kitchen

• Train employees on disabling freezer lock• Splash goggles for handling cleaning liquids• Packaging machines – finger entrapment hazards• Hobart mixer unguarded• Eyewash needed• Secure furniture against tipping• Need IIPP, and Hazard Communication Programs

Example: Spice Packaging

• Blocked access to electrical panels• Openings in electrical panels• Lock-out/ tag-out procedures• Review and implement IIPP• Voluntary respirator use without training• Secure furniture• Blocked fire extinguishers• Complete Log 300s

Example....

• Exit door needs panic hardware• Liquid nitrogen tank in shipping is unsecured• Ventilation in shipping room not tested annually• Repair oxygen sensor• Improve IIPP• Recommendation: improve ergonomics of lifting

sample racks from cryogenic storage tank.

Elements of an On-site Consultation

• Preparation • Opening conference• Review Safety Record – Log 300, etc. • Program Review • Walk Around• Closing Conference• Report• Hazard Correction

Review Safety Record

Review Log 300s Reportable injuries Near misses

• Documentation ?• Duplicate injuries?• What changed as result?• Programs implemented?• On-going major concerns/

safety focus ?

Injury & Illness Prevention Program(IIPP)

• A primary focus of Cal/OSHA• Required only in CA• Overall in-house safety program• Includes the required elements (§3203)• Tailored to the company’s safety needs• Implemented and documented

IIPP Elements (§3203)

• Responsibility• Employee Compliance• Safety Communication• Workplace Inspection• Injury and Illness Investigation• Hazard Correction• Training and Instruction

IIPP

• Tailored to your needs• Short and to the point• Reviewed & Modified (coffee stains are a plus)

• Do what you say; say what you do …• Concise documentation

Quality Safety Meetings

• Required only for construction work • Should be common in all businesses• Good way to meet IIPP safety communication

requirement• Often a missed opportunity to make a real

difference

Quality Safety Meetings

• In language that can be understood• Relevant to what’s happening or going to• Involves employee participation• Demonstration, show and tell• Management follow through• Rotate responsibility for leading and presenting

What level are you at ?

• “911” Safety Program• “Big Binder” Safety Program • “Doing it for OSHA” Safety Program • “Safety Nag” Program• “Safety Culture” Program

Safety Culture

• Shared high expectations• Shared sense of responsibility • Mutual accountability • Shared drive to improve• Shared ownership

Quality Safety Meetingsas building Safety Culture

• In language that can be understood• Relevant to what’s happening or going to• Involves employee participation• Demonstration, show and tell• Management follow through• Rotate responsibility for leading and presenting

Other Written Safety Programs ?

• Chemical Hazard Communication• Emergency Medical Services (Construction)• Heat Stress (Outdoor work)• Bloodborne Pathogen Exposure Control • Permit-Required Confined Space• Respiratory Protection • Lock-out / Tag-out Procedures• Aerosol Transmissible Diseases

Why Written Programs?

A. The more safety binders, the better B. The bigger the safety binders, the better C. I really don’t have enough to do D. It intimidates everyone else E. Cal/OSHA just loves this stuff F. All of the above

Why Written Programs?

Written programs should ensure that:

• All aspects have been thought through;• Document actions are fully responsive to regulation • Responsibilities have been assigned;• Maintain institutional memory.

They serve as the basis for employee education Documentation of implementation is just as important! Don’t descend into ‘safety binder fetishism’

Walk Around Inspection

• Machine guarding• Fall hazards• Secure furniture, racks, equipment• Electrical hazards• Eyewash installation and flushing• Personal protective equipment• Compressed gas cylinders• Fire extinguishers

Walk Around Inspection

• Forklift operators• Obstructed emergency exits• Audit exhaust ventilation annually• Dust conveying ducts – clean-out ports• Chemical hazards not assessed• Noise hazards not assessed• First aid trained personnel

Resources

http://www.dir.ca.gov/dosh/PubOrder.asp

Or google: Cal/OSHA publications