Be warned! You could be on OSHA’s inspection and enforcement “hit list.” The agency will soon announce its 2008 Site-Specific Targeting (SST) plan that will focus on unannounced comprehensive of inspections high-hazard worksites in the 29 states covered by OSHA rules — it does not include companies targeted for inspection by state agencies in the 21 states that administer their own safety and health programs.
Here’s a five-step program to evaluate your chances of getting a visit from OSHA:
Step 1. Check your own injury and accident rates. Take a close look at your organization. Review your accident statistics, injury and illness logs, and incident rates, particularly your Days Away, Restricted, and Transferred (DART) rate, and Days Away from Work Injury and Illness (DAFWII) rate. You can determine your DART and DAFWII rates from the OSHA Form 300 log and Form 300A Summary.
Step 2. Look at OSHA’s trends in citations and violations for your industry. Go to the OSHA Website and review statistics about trends in citations and violations for your industry or for all workplaces. You can look at the number of citations for a particular regulation and, in some cases, right down to a paragraph within a regulation. To browse through the regulations that cover your industry, go here.
Step 3. Compare your incidence rates with those of your competitors. You can find the history of inspections of your competitors on the OSHA site here. The database also contains the list of citations by regulation number. Don’t forget to look at the General Duty Clause (GDC) citations. OSHA uses the GDC to cite any activity creating a hazard that’s not covered under a specific regulation, such as many activities that cause musculoskeletal disorder hazards.
Step 4. Determine whether you’re making the news. OSHA inspectors respond to news stories about an organization, even when the news is positive. In one case, a company was highlighted in a news story for the benefits it was providing to the community, but the images on TV showed some construction activity in the background that looked suspicious to someone who called OSHA. An inspector went out to the site and found violations.
If a news agency makes inquiries and wants information about you, carefully screen any comments or photographs given to it. Even a positive news story can inadvertently sting you when it comes to workplace safety and health.
Also, track news stories in your industry or geographical area that relate to workplace safety, especially stories about accidents and penalties. They can alert you to problems at your own facility and give you time to fix them before OSHA finds you.
Step 5. Monitor what’s new with OSHA. Keep an eye on OSHA’s Special Emphasis program for targeting certain high-hazard industries.
