Pretest

1
Index

• Title Page
• Pre-test
• Primer on Cal/OSHA Regulations
• Preparing for an inspection
• IIPP
• Respiratory Program
• Emergency Action Plan
• Lockout-Tagout
• Medical Services
• Required Posters
• Recordkeeping
• Training Requirements
• Field Sanitation
• The End

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Cal/OSHA Regulatory Reality CheckDont Loose
Something in the Translation
3
Primer on Cal/OSHA Regulations

• Industry Safety Orders
• 23 Subchapters
• Unfired Pressure Vessel
• Construction
• Electrical
• General Industry Safety Orders (GISO)
• And 19 more.

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Primer on Cal/OSHA Regulations

• So where do you begin?

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Primer on Cal/OSHA Regulations

• First
• General Industry Safety Orders (GISO) applies to
  all employers
• Horizontal standards
• Example
• GISO 3203 Injury and Illness Prevention
  Program
• GISO 3220 3221 - Emergency Action and Fire
  Prevention Plan

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Primer on Cal/OSHA Regulations

• Second
• Specific Industry Safety Orders
• Vertical standards
• Example
• Agricultural Operations
• Grouped in Article 13

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Primer on Cal/OSHA Regulations

• Third
• Dont assume a vertical standard doesnt apply to
  you
• Example
• Construction standards
• Trenching
• Demolition
• Fall Protection

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Primer on Cal/OSHA Regulations

• Fourth
• Vertical take precedence over horizontal
  standards
• When vertical is silent you must look to
  horizontal orders
• Example
• 3439. First-Aid Kit Article 13 Ag.
• 3400. Medical Services and First Aid.

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Where to find information

• Title 8 Safety Orders On-line
• http//www.dir.ca.gov/Samples/search/query.htm
• Cal/OSHA Policy and Procedures
• http//www.dir.ca.gov/samples/search/querypnp.htm
• Cal/OSHA Recordkeeping
• http//www.californiaosha.info/
• Cal/OSHA Publications
• http//www.dir.ca.gov/dosh/PubOrder.asp
• Hans Boersma

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Cal/OSHA Inspections

• Preparing for a Cal/OSHA Inspection
• Your rights when Cal/OSHA visits
• Dual Employer vs. Multi-Employer
• What to do now to prepare for an inspection
• What to do when inspected
• What to do after an inspection

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Cal/OSHA Pre-test

• How many days prior to an inspection will
  Cal/OSHA notify you of the inspection?
• None!
• An Inspection will be triggered by
• A. An employee filed a complaint?
• B. You had a serious accident?
• C. Because youre an agricultural operation?
• D. Because youre so likable?
• D. All of the above?
• D - Whats there not to LIKE?

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Cal/OSHA Pre-test

• What is your response to a Cal/OSHA inspector
  when asked Do you have .
• An IIPP?
• A Hearing conservation program?
• A Hazard communication program?
• Cal/OSHA Forms 300, 300a 301?
• Your Answer is...
• YES!

13
Your Rights

• By law Cal/OSHA will not give you an advance
  notice
• You may consent to an inspection, or
• You may demand an administrative search warrant
• But expect An Attitude from the inspector

14
Dual Employer vs. Multi-Employer

• Dual-Employer
• PP C-1D (FLC relationship)
• http//www.dir.ca.gov/DOSHPol/PPC-1D.HTM
• Supervision and Control
• MSWPA - Joint-Employment
• Economic dependency
• Supervision and control

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Dual Employer vs. Multi-Employer

• Multi-Employer
• PP C-1C
• http//www.dir.ca.gov/DOSHPol/PPC-1C.HTM
• Common worksite
• Liable for injuries of another companys
  facilities
• Exposing employer - Employer of exposed employees
• Controlling employer - Causes the exposure
• Written contract - Behavior controls
• Describes responsibilities
• Communications

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Preparing for an inspection

• Assign management responsibilities
• Inspection supplies
• Notebook
• Camera
• Tape recorder
• Flashlight
• Lockout/Tagout Supplies
• Inform employees and supervisors to direct ALL
  visitors to the office

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Preparing for an inspection

• Make sure employees understand
• Safety procedures
• Rate of pay
• Hours of work
• Perform self inspections (Document)
• Perform employee safety training (Document)

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Preparing for an inspection

• Request Workers Compensation carrier to inspect
  facilities
• Request Cal/OSHA Consultation for assistance
• Know General Industry Safety Orders for your
  operation
• www.osha-slc.gov/html/subject-index.html
• www.dir.ca.gov/samples/search/query.htm
• www.dir.ca.gov/DIR/OSH/DOSH/dosh_publications/IND
  EX.html

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Preparing for an inspection

• Know where to locate your
• IIPP other written programs. Consult Cal/OSHA
  form 1AY
• Training records
• Inspection records
• MSDS, Forms 300, 300A and 301
• Post required notices
• Post warning signs and instructions

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When Cal/OSHA Inspects You

• Be polite to the inspectors
• Do not physically detain or bar the person from
  entering the property
• Record the date, the time, and the location of
  inspection
• Verify the inspectors credentials. Person could
  be CRLA not Cal/OSHA
• If CRLA move employees away from public areas.

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When Cal/OSHA Inspects You

• If unsure call the agencys office. Consult a
  telephone directory
• If inspection is not convenient ask the inspector
  to return later
• Attempt agreement on the scope of the inspection
  in writing
• Avoid full access to any and all records and
  locations

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When Cal/OSHA Inspects You

• Accompany the inspector
• Wont be allowed to listen in on employee
  interviews
• Photograph facilities or equipment of concern to
  inspector
• Make written notes of the inspectors comments
• Tape record your conversations, if permitted

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When Cal/OSHA Inspects You

• After the inspection request a closing meeting
• Make sure you understand the inspectors concerns
• Fix identified problems as soon as possible.
• Develop company policy regarding visitors.

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If You Receive a Citation

• Appeal unwarranted citations
• Wrong section cited
• Employees statements misleading
• Inspector trespassed
• Independent Employee defense
• Video - Handling Your Appeal
• Send 6.00 to Cal/OSHA Appeals Board
• 2520 Venture Oaks Way, suite 350
• Sacramento, CA 95833, [phone]

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Written Injury Illness Prevention Program (GISO
3203)

• Designate a person
• Ensure employee compliance
• Communication with employees encourage
  employees to inform you of hazards
• Identifying hazards
• Investigation of injuries and illnesses
• Correcting unsafe conditions
• Procedures to train and instruct employees

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Respiratory Program (GISO 5144)

• Assign a person to administer program
• Engineering controls where feasible
• Approved equipment
• Education and training
• Inspection before use
• Maintenance, sanitation and storage
• Selection and issuance of respirator
• Medical limitations
• Respiratory protection program (written)

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Hazard Communication Program (GISO 5194)

• Written Hazard Communication Program
• List of hazardous substances
• Methods to inform employees of non-routine tasks
• Procedure to insure containers are labeled
• Identity of substance
• Appropriate hazard warnings
• Prop 65 warnings
• Procedure to acquire MSDS and make available to
  employees
• Procedure to train employees

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Emergency Action Plan (GISO 3220)

• Written procedures if company has emergency
  procedures
• Ten or fewer employees plan can be communicated
  orally
• Training of employees
• Fire prevention (GISO 3221)
• Written plan
• Extinguishers located in flammable areas
• Extinguishers inspected
• Employees trained in extinguisher use

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Lockout/Tagout

• Written energy control procedures
• An employee training program
• Periodic inspection procedures
• Annual audit

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Medical Services (GISO 3400)

• Must provide medical services within 4 minutes
• Otherwise, must have a person trained in
  CPR/First Aid
• Agriculture - one CPR/First Aid trained person
  per 20 employees at remote locations
• Supervision at isolated locations
• Adequate first-aid materials approved by company
  physician
• Facilities for drenching or flushing of eyes or
  body

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Required OSHA Posters

• "Safety and Health Protection on the Job"
• "Emergency" phone numbers S-500
• "Access to Medical and Exposure Records" S-11
• Notice to employees regarding
• Location of MSDS's
• Location of Hazard Communication Program
• Name of person responsible for IIPP

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Required OSHA Posters

• "Agricultural-Industrial Tractors" GISO '3664
• "Operating Rules for Industrial Trucks" GISO
  '3657, 3659 and 3664
• "Log and Summary of Occupational Injuries and
  Illnesses" OSHA 300A (Post from February
  through April)
• Field sanitation notice

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Required OSHA Posters

• Prop 65 warning notice
• Emergency signs e.g., fire extinguishers, exiting
  from buildings, or other appropriate warnings

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Recordkeeping and Reporting Requirements

• Cal/OSHA Recordkeeping
• OSHA 301 (11 or more employees) or DOSH 5020 rev
  7
• OSHA 300 Summary of Injuries and Illnesses
• OSHA 300A Annual Summary - Posted Feb. - April.
• Inspection records
• Review of accidents or illnesses

35
Recordkeeping and Reporting Requirements

• Communications with employee - response to
  employee suggestions
• Employee safety warnings - employee recognition
  program
• Correction of hazards
• Training and instructions
• Medical records - chemical exposure, etc.

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Reporting Requirement

• Report serious accidents to Cal/OSHA within 8
  hours
• Injuries requiring 24-hour hospitalization
• Dismemberment
• Death
• Minimum 5,000 fine

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Safety Training

• New employee orientation
• Workers' Compensation Insurance coverage
• Provide Physician Pre-designation form
• Work rules
• Emergency procedures
• Hazard communication program
• Good hygiene practices, etc.
• Job specific training at time of hire

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Safety Training

• When assign a new task
• When a new substance, process, procedure or
  equipment is introduced
• When an unrecognized hazard becomes known
• Annual tractor operator training, GISO 3664
• Familiarize supervisors of hazards

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Specific Training Requirements

• Equipment tractor, forklift
• Tractor annual - 3664 vs. 3668 Forklift
• Emergency action plan training
• Fire prevention, fire extinguisher
• Lockout/Tagout
• Respirator users
• Confined space entrants and rescue teams
• Battery charging

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Specific Training Requirements

• Bloodborne pathogens, doesnt apply to
  agriculture
• Hazard Communication

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Sanitation Facilities

• Alternative Compliance (lt5 employees, lt2 hours)
• Drinking Water-Readily Accessible
• Toilet and Handwashing-1/4 mile or 5 minutes
• One per sex, 5 or more in crew
• One per 20 employees per sex
• Maintenance Records (2 years)
• Employee Notices hand-washing water only, good
  hygiene

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Thank you!

• George Daniels
• Farm Employers Labor Service
• [phone]
• www.fels.org