How OSHA Inspectors Think
Here are a few things that I like to call ‘low-hanging fruit’ for OSHA inspectors—circumstances that are common, obvious, and simple for employers to correct.
I witnessed each of these events firsthand in my role as an OSHA investigator, resulting in frequent ‘write-ups’. It’s safe to say that at least one of these standards violations was present in each work environment I visited; over time, they became easier and easier to spot.
So this is to help you understand basic compliance/enforcement activity. Do me a favor after reading this: identify and correct these hazards in your workplace, if they exist…
Lock & Tag Procedural Documents
What did I commonly cite when I was an OSHA Inspector? Here’s one:
Do you have written, step-by-step, lock-out/tag-out procedures for each & every piece of equipment with more than one energy source? If not, know that you are required to have them. Also, these written procedures must include instructions for safely energizing and de-energizing each piece of equipment.
#1. Gravity is an energy source! Remember this, as it is often and easily overlooked.
#2. Ensure that your employees have ready access to all procedural documentation, and that they have been trained to use and follow procedure without failure, even when under duress or working quickly. Safety Friends—this is not an easy task, I know. If so inclined, please share your templates, resources and tips for handling this area with your fellow safety professionals.
Here are the sections I cited when procedures were missing: 1910.147(c)(4)(i) and (ii)(A-D)
Extension cords used in place of permanent wiring…see it all the time!
On inspections, my eyes were trained to look for blue, orange, yellow, green—the common colorations of extension cords, meant for high-visibility. There are, of course, those really low-cost, two-wire, kinds of extension cords, in either brown or white. Those are the kind where you can scrape the insulation off with your fingernail.
Now, I’d find various types of extension cords strung along ceilings to power fluorescent light fixtures, for example. And I’d find them zip-tied to work benches and conduit or passing through doors just waiting to be squished again and again against a metal door frame. I’d see them snaked through a hole that had been carved through a wall, and multiple extension cords strung together to power all manner of electrical devices.
In fact, I saw so many of them, so frequently, that I nearly made a game of finding an extension cord used in a new, unsafe manner. So how many can you find in your workplace? Give it a try on your next safety audit.
This is the primary regulation I cited: 1910.305(g)(1)(iv)(A)-(F) Unless specifically permitted otherwise in paragraph (g)(1)(ii) of this section, flexible cords and cables may not be used…
Hazard Assessments for Personal Protective Equipment (PPE)
Did you know you are required to do a hazard assessment to determine PPE needs? Did you know that you need those assessments in writing?
See 1910.132(d)(2): ‘The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.’
As an investigator, I’d ask each employer how they determined XYZ was the correct respirator for a certain job function and would ask to see the written certification/document proving an assessment of some sort was actually performed. Basically, I was asking for proof that there was thought behind a PPE choice—or decision not to use PPE— based on hazard exposure.
And that’s what the law requires.