['Safety and Health Programs and Training']
['Safety and Health Programs and Training']
01/02/2024
Copyright 2024 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.
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If you need help recognizing and correcting safety and health hazards or improving your company’s safety and health program, OSHA’s free consultation service may be the answer. It uses highly qualified safety and health professionals who provide vital information and technical assistance to help you evaluate and prevent hazardous workplace conditions.
The service, largely funded by federal OSHA, is a broad network of safety and health services delivered by the state governments. The comprehensive assistance that is available goes well beyond the minimum requirements of OSHA regulations. It includes an appraisal of all mechanical systems, physical work practices, environmental hazards of the workplace, and all aspects of an employer’s present job safety and health program. In many instances, training and education for the employer, supervisors, and employees is also provided.
A cooperative approach
Consultation is primarily targeted for smaller businesses in higher hazard industries or with especially hazardous operations that often lack the financial resources to hire outside private consultants to help them identify and correct hazardous situations. The program is completely separate from enforcement operations and only in rare instances does OSHA ever issue citations for hazards identified by the consultant, and no penalties are ever proposed.
The service is confidential, too. Your name and firm and any information about your workplace, plus any unsafe or unhealthful working conditions that the consultant uncovers, will not be reported routinely to the OSHA inspection staff. Nor will your request for a consultation trigger a federal or state inspection.
Your only obligation is a commitment to correct imminent dangers and other serious job safety and health hazards in a timely manner. You make this commitment before the consultant’s visit.
Consultation is a cooperative approach to solving safety and health problems in the workplace. As a voluntary activity, it is neither automatic nor unexpected. You must request it. In addition to a full consultation, OSHA also offers limited service consultation which gives you the option of limiting the consultation to a discussion of fewer, more specific problems.
Benefits
The price is right! The service is free to eligible employers. Federal OSHA, in partnership with the states, designed and fund this program to provide expert advice to more hazardous, smaller businesses that want help in establishing a safe and healthful workplace.
When you know what workplace hazards you’re dealing with and how to remedy them, you’ll be in a better position to comply with safety and health requirements, decrease injuries and illnesses, experience fewer product losses, reduce down-time, and ultimately reduce your workers’ compensation costs. The more you know about the safety and health aspects of your company’s operation — and ways to improve them — the better you can manage in general. The consultation program provides professional advice and assistance without the need to hire additional staff.
When a consultant helps set up or strengthen a workplace safety and health program, safety and health activities become routine considerations rather than crisis-oriented responses. And, in recognition of your efforts, you may be excluded from general schedule OSHA enforcement inspections for one year when you have a complete examination of your workplace, correct all identified hazards, post notice of their correction, and institute the core elements of an effective safety and health program.
Consultation — More than just an assessment
Consultation is a two-way process — the consultant will be both student and teacher. The consultant will carefully study your workplace and the safety and health program in order to apply professional expertise to specific problems unique to your operations.
Consultation can go beyond the usual physical survey of the workplace for violations of OSHA standards. The consultant may also point out work practices that are likely to cause illness or injury and then advise and assist your company in correcting them. Other preventive suggestions may be directed toward improving your occupational injury and illness experience, such as self-inspection, supervisory responsibility in promoting safety, safety and health training needs, posters to help in alerting workers to hazards, labor-management safety and health committees, and regular safety and health meetings with workers.
Comprehensive consultation services include:
- Appraisal of all mechanical and environmental hazards and physical work practices.
- Appraisal of the present job safety and health program or the establishment of one.
- Conference with management on findings.
- Written report of recommendations and agreements.
- Training and assistance with implementing recommendations.
- Follow-up to assure that any required corrections are made.
How to start
How does this process begin? Consultation starts with your request — by telephone, letter, or a personal contact. The consultation office determines the priority of your request for services — the most hazardous sites receive top priority. Some services, such as a review of proposed new production processes from a safety and health point of view, may be conducted at locations away from the employer’s worksite.
When you request onsite services, the consultant will confer with you at the outset regarding the specific needs or concerns you describe. The consultant may also research any special problems you mention in the initial contact before scheduling a visit to your establishment.
Although the consultant may encourage you to include within the scope of such a request all working conditions at the worksite and your entire safety and health program, you do have the option to limit the visit to one or more specific problems. However, if the consultant observes a hazard which is outside the scope of the request, he or she must notify you of its presence.
Opening conference
Upon arrival at your workplace for a scheduled visit, the consultant will briefly review what will occur during the visit and may, if requested, review with you your safety and health program. The consultant will explain the relationship between onsite consultation and OSHA enforcement activity and your obligation to protect employees in the event that serious hazardous conditions are identified.
As part of the consultation process, consultants have the right to interview your employees, either privately or at their workstations. At this point, the consultant will review this right and you must agree to permit such contact before the visit may proceed.
OSHA strongly encourages, but does not require, employee participation in each step of the consultative visit, from opening conference to site walkthrough and closing conference. Better informed and alert workers can more easily work with you to identify and correct potential injury and illness hazards. In unionized work areas, you must give employee representatives the opportunity to participate fully in the consultation process.
Walkthrough process
During this process, you and the consultant will examine conditions in your workplace. The consultant will identify any specific hazards and provide advice and assistance in establishing or improving your safety and health program and in correcting any identified hazardous conditions. At your request, assistance may also include education and training for you, your supervisor(s) and your employees.
The consultant will study either your entire operation or focus on those areas, conditions, or hazards for which you have requested assistance, including hazards not covered by current OSHA standards but that still pose safety or health risks to your employees.
During the review of your company’s operation, the consultant will:
- Look for physical hazards by examining the structural condition of the building, the condition of the floors and stairs, and the exits and fire protection equipment.
- Review the layout for adequate space in aisles and between machines.
- Check for proper control of electrical and mechanical hazards.
- Survey the controls used to limit worker exposure to occupational health hazards, including toxic and corrosive substances and especially air contaminants.
- Check that necessary personal protective equipment is available, functioning properly, and that employees know how to use and care for it.
- Note any problems associated with exposure to noise, vibration, extreme temperatures, lighting, or other environmental factors.
- Review work practices, including general housekeeping, the maintenance and repair of equipment, handtools, portable power tools, and forklift operations.
- Review company procedures for worker job training (including safety and health orientation and ongoing training), supervision, accountability for safety and health, first aid, and hazard reporting.
As the walkthrough assessment proceeds, the consultant will not only note problem areas but will discuss prevention and control techniques on the spot. Management and worker attitudes toward safety and health will be considered in the final analysis, as well as current injury and illness data.
Closing conference
Following the walkthrough, the consultant will meet with you for a closing conference. This session gives the consultant an opportunity to discuss measures that are already effective in your workplace and any practices that warrant improvement. During this time, you and the consultant can discuss problems, possible solutions, and time frames for eliminating or controlling any serious hazards identified during the visit.
In rare instances, a consultant may find an “imminent danger” situation during the walkthrough. If this happens, your company must take immediate action to protect all affected workers. If a hazard that is considered to be a “serious violation” under OSHA criteria is noted, the consultant will work with you to develop a mutually acceptable plan and schedule to eliminate or control that hazard. During this time, OSHA encourages you to advise all affected employees of the hazards and to notify them when the hazards are corrected.
Consultants offer general approaches and options as well as technical assistance on the correction of hazards when they have the expertise. As necessary, consultants recommend other sources for specialized technical help. They may also offer suggestions for establishing, modifying, or adding to the company’s safety and health program in order to make such programs more effective. Such suggestions could include:
- Worker training,
- Changing work practices,
- Methods for holding supervisors and employees accountable for safety and health, and
- Various methods of promoting safety and health.
Correcting the hazards
After the closing conference, the consultant will send your company a written report explaining the findings and confirming any correction periods agreed on. The report may also include suggested means or approaches for eliminating or controlling hazards as well as recommendations for making your safety and health program effective. You are, of course, free to contact consultants for additional assistance at any time.
Ultimately, OSHA does require completed action on serious hazards so that each consultation visit achieves its objective — effective worker protection. If an employer fails or refuses to eliminate or control an identified serious hazard (or any imminent danger) according to the plan and any extensions granted subsequently, the situation would be referred from consultation to an OSHA enforcement office for review and action as appropriate. This is a rare occurrence.
Participation in the Consultation Program benefits your company
Onsite consultants WILL:
- Help you recognize hazards in your workplace.
- Suggest approaches or options for solving a safety or health problem.
- Identify sources of help available to you if you need further assistance.
- Provide you with a written report that summarizes these findings.
- Assist you in developing or maintaining an effective safety and health program.
- Offer training and education for you and your employees at your workplace, and in some cases away from the site.
- Under specified circumstances, recommend you for recognition by OSHA’s SHARP program and a one-year exemption from general scheduled enforcement inspections.
Onsite consultants WILL NOT:
- Issue citations or propose penalties for violations of federal or state OSHA standards.
- Routinely report possible violations to OSHA enforcement staff.
- Guarantee that any workplace will “pass” a federal or state OSHA inspection.
Contact your State Consultation Office
Consultation is a highly successful program that generates employer response. If you would like to receive additional information, contact your State Consultation Office or your OSHA Regional Office.
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Copyright 2024 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.