Cal/OSHA Consultation Service On-Site Visits

1
Cal/OSHAConsultation Service On-Site Visits

• Peter Scholz, MPH, CIH
• Assoc. Safety Engineer
• Oakland Area Office

2
Cal/OSHAConsultation vs. Enforcement

• Confidential (very limited exceptions)
• No fines or citations
• No cost
• Agreeing to fix any hazards found that is not
  voluntary.

3
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

4
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

5
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

6
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.

7
Elements of an On-site Consultation

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

8
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 ?

9
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 companys safety needs
• Implemented and documented

10
IIPP Elements (3203)

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

11
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

12
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

13
Quality Safety Meetings

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

14
What level are you at ?

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

15
Safety Culture

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

16
Quality Safety Meetingsas building Safety
Culture

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

17
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

18
Why Written Programs?

• A. The more safety binders, the better
• B. The bigger the safety binders, the better
• C. I really dont have enough to do
• D. It intimidates everyone else
• E. Cal/OSHA just loves this stuff
• F. All of the above

19
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!
• Dont descend into safety binder fetishism

20
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

21
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

22
Resources

• http//www.dir.ca.gov/dosh/PubOrder.asp
• Or google Cal/OSHA publications