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Put OSHA
response into your written safety plan, policies &
procedures
Safety Advantage Clients with
programs in place have first-hand experience with our
recommendations for placing OSHA response protocols
directly into their company's written safety and health
programs.
Approximately one third of our new Client
roster last year consisted of
employers we met when called in to assist with an OSHA
intervention.
OSHA response protocols would have
dramatically helped two of these new Clients be much
more informed and better
represented when the compliance officer came through
the front door.
Client's
who write specific OSHA response protocols into their
written safety programs give their supervisors and first
response personnel a valid and understandable reason to
postpone a non-warrant inspection until designated
company safety personnel and the consultant are on site
to accompany the officer.
Compliance officers are more
inclined to work within this policy when they understand
it will give them more accurate information about the
Client's safety operations. Additionally, an
officer is usually not comfortable in asking employer
personnel to disregard requirements in their company's
written safety program.
The two new Clients were
confronted with situations and circumstances that
ultimately led OSHA to pursue "willful" violations with penalties tens
of thousands of dollars higher than would be expected
from serious violations alone.
Each of these employers would have
been GREATLY assisted by having OSHA response protocols in place
when the compliance officer arrived on site.
Neither had supervisors trained or prepared to handle an
inspection.
Also, neither Employer was able to
get knowledgeable representatives on
site in time to accompany the
compliance officer, to respond effectively to
questions and situations
observed.
Although citations and penalties
have yet to be issued in these inspections, both
employers were told by their local OSHA offices that
violations observed were "a very big problem" and
citations are likely to exceed $150,000.
Although such total penalties are "big ticket"
items for many employers, for one of
the two new Clients the OSHA fines could be secondary considerations. This company,
a construction subcontractor, is much
more concerned about OSHA's contacts to its
primary host employer, the anticipated citations and
publicity that could adversely affect future contracts and an
upcoming insurance renewal. Problems with
contracts and insurance could have multi-million-dollar
consequences, the company owner believes.
Clients with specific questions or
concerns about their OSHA response preparedness can
call Paul Fontenot or Jim Giles at 800.960.1239 or
713.977.5690.
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