presented by: scott d. cole, leed ga, coss, csp osha inspections

21
Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

Upload: alicia-craig

Post on 17-Jan-2018

223 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

Presented By: Scott D. Cole, LEED GA, COSS, CSP

OSHA INSPECTIONS

Page 2: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS
Page 3: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS
Page 4: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS
Page 5: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS
Page 6: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

ObjectivesWhen Can I Expect an OSHA Inspection?How Can I Prepare for an OSHA

Inspection?How Should I Handle an OSHA

Inspection?How Do I Close an OSHA Inspection?

2016 OSHA Citation Structure

Page 7: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

Who is OSHA?

$592MM in 2016

7.3% Increase

37,785

Chemical Facilities

Page 8: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

Why Would OSHA Inspect?CatastropheEmployee complaintProgrammed inspections

http://www.osha.gov/as/opa/foia/hot_11.html Invitation

Page 9: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

Preparing Your OrganizationWritten programDrillsKnow your rights!

Page 10: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

What Are My Employees’ Rights?Representation at opening and closing

conferenceRepresentation during the inspectionPrivate interviewsWhistleblowers protection

Page 11: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

Managing the InspectionWarm welcome or demand a warrant?IdentificationWhat is the purpose of the inspection?Offer a beverage and a comfortable work

spaceKill them with kindness

Page 12: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

The Opening ConferenceWho should be involved?Designate a scribeListenListenListenAnswer direct questionsDocumentation – know what’s required

Page 13: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

The Physical InspectionAssemble your best teamPlan a route of travelTake photosFix it ASAPEmployee interviews

Page 14: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

Physical ConditionsHousekeepingGuardingFall protectionIlluminationSanitationSignageSafety equipment

Page 15: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

DocumentationOSHA logsExposure recordsWritten programs, SOPs, JHAs, etc.Training recordsMedical recordsDiscipline log

Page 16: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

Written Programs – Not All-InclusiveHazard

CommunicationsRespiratory ProtectionHearing ConservationLockout / TagoutConfined SpaceBlood Borne

PathogensPPEExcavation Safety

Fire and Emergency Evacuation

Access to Employee Medical Records

Fall ProtectionElectrical SafetyLadder SafetyScaffold SafetyCrane Safety

Page 17: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

The Closing ConferenceDesignate a scribeListenListenListenAsk but don’t argueDon’t make promisesThank you

Page 18: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

The CitationReviewDocument corrective actions, if any and

postRequest an informal conference

Formal letterFile a Notice of Intent to Contest

15 business daysStep 1 – Administrative Law JudgeStep 2 – Full OSHRCStep 3 – US Circuit Court of Appeals

Page 19: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

PenaltiesDependent upon how likely the violation is

to result in serious harm to employees Other-than-serious

$0 - $7,000Serious

$0 – 7,000Repeat and Willful

$0 - $70,000

Page 20: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

August 1, 2016 PenaltiesDependent upon how likely the violation is

to result in serious harm to employees Other-than-serious

$0 - $12,000Serious

$0 – 12,000Repeat and Willful

$0 - $125,000

Page 21: Presented By: Scott D. Cole, LEED GA, COSS, CSP OSHA INSPECTIONS

Questions?

THANK YOU

Scott D. Cole, LEED GA, COSS, CSPSteering Committee – Lake County Safety Council

V. President – Northern Ohio Chapter of the American Society of Safety Engineers

President – Cole Safety ServicesBusiness Unit Safety Director – Turner Construction Company

[email protected]