Over the years I have been asked by many of my clients this very important question. What documents will an OSHA inspector ask me for? Occupational Safety and Health Administration (OSHA)record keeping involves maintaining several mandatory written programs and records. The following is a management checklist of the 10 most common written programs and records that an OSHA inspector might ask to see.
1. OSHA 300 Log ' If you have 10 or more employees, you need to keep an OSHA 300 Log (29CFR1904). The OSHA log is a uniform way of providing information to the Bureau of Labor Statistics (BLS). Determining if an injury is a first-aid case, a recordable injury or illness, or a lost-workday case is not always an easy task. Make sure that whoever is in charge of keeping your OSHA 300 Log reads and understands the OSHA guidelines. In many cases, good case management and knowledge of the recordkeeping rules can save you a recordable injury.
2. Lockout/Tagout Program ‘The purpose of a lockout/tagout program (CFR1910.147) is to ensure the safety of personnel by preventing equipment activation anytime maintenance or repair work is being performed. Programs must be designed to protect the safety of employees working on or close to equipment with the potential for unexpected operation, movement, release of energy, or release of hazardous materials.
3. Process Safety 'OSHA's Process Safety Management Standard (CFR1910. 119) establishes requirements that employers must follow to prevent catastrophic losses associated with certain chemical processes. Some of these requirements include employee training, prestart safety reviews, mechanical integrity inspections, and emergency planning and response. The standard applies to any process involving one or more of the listed highly hazardous chemicals (such as ammonia, hydrochloric and hydrofluoric acids, hydrogen, and propylene) at or above the threshold quantity or any process that involves a flammable liquid or gas in a quantity of 10,000 pounds or more.
4. Emergency Action Plan 'OSHA requires that action plans (CFR1910.38) be in writing. The plans must cover actions that designated employers and employees are expected to take to ensure employee safety from fire and other emergencies. The plans should identify potential emergency situations and convey to employees just what their responses should be.
5. Respirator Program 'If respirators are necessary in your workplace to protect the health of employees, you must establish and implement a written respiratory protection program (CFR1910.134) with work site-specific procedures. The program must be updated as necessary to reflect changes in workplace conditions affecting respirator use.
6. Confined Space 'Workplaces must be evaluated to determine if any spaces are permit-required confined spaces. If employees enter permit-required confined spaces, a written confined-space program that complies with CFR1910.146 must be developed and implemented. The written program must be available for inspection by employees and their authorized representatives.
7. Portable Fire Extinguishers 'Ensure that all portable fire extinguishers undergo an annual maintenance check (CFR1910.157). Record the annual maintenance date and retain this record for one year after the last entry or for the life of the shell, whichever is less. The record must be available upon request.
8. Hazard Communication (HazCom) 'Through a formal, written hazard communication program (CFR1910.1200), an employer must assess chemical hazards in the workplace to which employees may be exposed.
9. Hazard Assessment 'Assess the workplace to determine if hazards are present, or are likely to be present, that necessitate the use of personal protective equipment (PPE). You must ' verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated, the person certifying that the evaluation has been performed, and the date(s) of the hazard assessment. Also, identify the document as a certification of hazard assessment (CFR1910.132).
10. Hearing Conservation 'If employees are exposed to noise levels at or higher than 85 decibels for a time-weighted average of eight hours, you must maintain records showing compliance with OSHA's Occupational Noise Exposure Standard (CFR1910.95). The records must contain the name and job classification of the employee, date of the audiogram, examiner's name, date of the last calibration of the audiometer, and the most recent noise exposure assessment for each employee. These records must be provided upon request to the employees, former employees, representatives designated by the individual employee, and the assistant secretary of OSHA. '
By Travis Costello, OHST
Costello Safety Consulting, LLC