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TELL US ABOUT YOUR OSHA EXPERIENCE
March 6, 2009
Have you been through an OSHA inspection lately? What happened and what did you learn from the experience? Please send your stories to glennd@bongarde.com. If you’re worried about putting your name or that of your company to the story, let us know and we’ll run the story anonymously.
Glenn Demby
Co-Editor-in-Chief
SafetyXChange
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OSHA inspection
As a NY state company, we fall under the Federal OSHA and we have always used the voluntary consultation services. Recently, I had a visit from a CO. I met him in our lobby and politely explained that we had an open inspection from the voluntary consultation services and from my understanding while we were working with them, we were exempt from another inspection. It took the next couple of hours for the two branches to conclude that I was speaking the truth and we were exempt. After that the consultation branch was told that following the close of the inspection, they were not allowed back. I took advantage of the “advanced notice” and went through my documentation with a fine tooth comb. We also spent a lot of time on the small stuff in the plant; fire extinguishers blocked, eye wash stations, electrical panels, etc. On our Flash Arc Program, I wrote out a schedule for compliance, survey dates, training, etc. so although we didn’t have a 100% program I could show how proactive we were being in pursuit of compliance.
When the actual date came that the inspector showed up, I felt I was ready. We had 6 full day visits over the next month, and in the end had some minor citations that we immediately abated. I was amazed at the cross checking that our auditor did, he took a specific job and checked the PPE hazard analysis, against the confined space procedure against the lockout procedure and the MSDS for the area. Before this experience, many times my audits and programs were written in “silos”. Although in this case, all my documentation matched hazards and procedures across the board, it wasn’t by design. I felt that it was a great learning point, and going forward I look at the jobs across the board, not the programs individually. This CO also spent more than 50% of the time speaking with our employees. I was not present in the room during the discussions, but he spoke with people from every shift and every department. As with previous articles, our experience was not a bad one, we were proactive on all issues and the CO that inspected our plant, recommended us to the area VPP coordinator as a prospective company. We still have a ways to go before we are at that level, but I was thrilled with the recognition.