What Do DOSH Inspectors Look For??

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The ABCs of DOSH Inspections
Holly Markee Approach Management
Services 253-208-1671
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Resources, Rights, Respect

• Why does the department choose to inspect your
  workplace?
• Inspection process
• Best practices for Employers

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Why Inspections Happen

• Imminent Danger
• Fatality/Accident
• Complaints/Referrals
• Scheduled Inspection

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Imminent Danger

• Reasonably expected to cause death or serous
  physical harm

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Fatality or Accident

• Accident injuries requiring hospitalization at
  least overnight of one or more employees.

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Notice of alleged hazard or violation of safety
health standard

• Complaint made by an employee

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Notice of alleged hazard or violation of safety
health standard

• Complaint made by an employee
• Referral by anyone else

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Scheduled Inspections

• High hazard/high claims industries such as
  construction and logging
• Industries with recent history of increased
• Individual companies with high injury/claims
• Individual companies that have not had an
  inspection recently

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Pre-Inspection

• Look at previous injuries and causes
• Look at all previous inspection history
• Look at your companies Experience Factor
• Any consultation history-POSITIVE

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Initial Stages

• Approach to your office/jobsite

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Initial Stages

• Approach to your office
• Introduction-Show credentials
• Permission to Inspect

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Initial Stages

• Approach to your office
• Introduction
• Opening Conference

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Making a Good Impression

• Have written programs readily available
• Give them a prepared visitor safety briefing
• Attitude
• Professional
• Courteous

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Walk-Around
Have the Describe how

• Look at equipment, machinery
• Observe processes employee activities
• Interview employees
• Determine if hazards exist

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H.E.C.K

• Hazard Is there a potential for injury?
• Exposure Have employees been exposed to the
  hazard? Or will likely be?
• Code Is there a safety code regarding the
  hazard?
• Knowledge Knowledge of the safety hazard by the
  employer.

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Observe Activities/Processes

• How do people typically do their jobs?
• Whats the flow of goods/services?

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Look At Equipment/Machinery

• Is it set up per manufacturers specs?
• Are there hazards?
• Guarding on machinery
• Inspections completed and documented?
• Electrical Hazards
• Is there Exposure?

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Look At Equipment/Machinery

• Is it set up per manufacturers specs?
• Are there hazards?
• Guarding on machinery
• Inspections completed and documented?
• Interlocks Switches Disconnected
• Is there Exposure?

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Fall Protection
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Hazard Assessment

• Welding Operation
• Proper Personal Protective Equipment?
• Welding Screens?
• Hand held grinders-Guards
• Is Respiratory Protection Required?

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Interview Employees

• Why
• Walk-Around Pay
• Discrimination
• How

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Interviewing

• Can they describe their safety training?
• How were they trained to do their particular
  jobs safely?
• Can they describe safety meetings?
• How would they report a hazard?

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Example Forklifts

• Is there a training program?
• Have employees had training?
• Written test and operational?
• Re-training for near misses?

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Example Hazardous Chemicals

• Is there a hazardous communication plan in
  writing.
• Is there an MSDS/SDS manual?
• Have the employees been trained?
• Is the training documented?

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Reviewing Documents - APP

• What does outlined in writing mean?
• Does APP address the actual hazards in the
  workplace?
• Is it effective in practice?

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Safety Committee/Safety Meetings

• Is there documentation that a safety committee
  has been established?
• Are their meetings documented?
• Have employee safety meetings been held?
• Are the meetings documented?

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Employee Records

• New employee orientation
• Training for the job
• Specialized training equipment or processes
• Medical records
• Respirator fit testing
• Audiometer testing

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Criminal/Willful

• The employer violated a WISHA standard
• The violation was willful in nature
• The violation of the standard caused the death of
  the employee

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Willful

• A willful violation exists when evidence shows
  either an intentional violation of WISHA or plain
  indifference to its requirements.
• 3X Repeat Serious is always evaluated as
  potential Willful

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Serious Violations

• A substantial probability that death or serious
  physical harm could result from a condition which
  exists.

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General Violations

• Hazard will not cause death or serious physical
  harm to employee, but does have a direct
  relationship to their safety and health.

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Grouping of Violations

• When one action corrects two hazards
• When two general violations combined create a
  substantial probability of serious physical harm
• When there are multiple violations of posting or
  recordkeeping requirements that involve the same
  document

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Repeat Violations

• Repeat violations exist whenever the previous
  violation involves a substantially similar
  hazard.
• Previous citation must be a final order
• Previous citation must be within three years

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Failure to Abate

• A violation from an inspection that has not been
  corrected as required.

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Program Violations

• APP- Must describe total safety program
• Hazard Communication program
• Confined Space Program
• Hearing Conservation Program

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De minimis Violations

• Employer complies with clear intent of standard

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Penalties

• Good Faith
• Size
• History

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Closing Conference

• Recap observed hazards
• Item-by-item review
• Employer input/explanation
• How to fix hazards

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Employers Can Make a Difference

• Find and fix before the inspector shows up
• Get active employee involvement
• Have all required programs
• In place developed by you with employees
• In use by your employees
• Be prepared
• -have a process in place
• Participate in the inspection as a way to avoid
  injuries expenses