The BWC Division of Safety & Hygiene’s OSHA On-Site Consultation Program OSHA On-Site Program Overview On-site consultants work with small, high-hazard employers to address the employer’s overall safety and health management system and to assist them in ensuring a safe and healthful workplace for their employees. o 90% federally funded o 10% state funded - Ohio Bureau of Worker’s Compensation Industrial Hygiene Services o Conduct noise surveys o Conduct air monitoring o Ventilation assessments o Provide advice as to the proper industrial hygiene/engineering controls OSHA On-Site Consultation o Similar to a federal OSHA inspection • • • • Opening conference Walk-through Closing conference A written report that summarizes the results of the visit Opening Conference o Rights and obligations explained • Hazard abatement deadlines • Interim protection o Full service consultation • • • • Facility walk-through Written program review Review of OSHA recordkeeping (300 logs) Safety and health management assessment Safety and Health Management Review o Conduct a safety and health program/policy review • • • • • • • Hazard anticipation and detection Hazard prevention and control Planning and evaluation Administration and supervision Safety and health training Management leadership Employee participation Walk-Through o Employee participation • For union shops, opportunity to participate in walk-through is required. o Discussion with employees • Required for all visits • To help assess safety and hygiene management • To help assess the extent of hazards Walk-Through o Scope of visits • Full service - look at all processes • Limited service - look at specific operations o Informal training Hazards Identified o Imminent danger situation • Abated immediately o Serious finding • Develop and agree to a reasonable plan and schedule to eliminate or control that hazard o Other-than-serious • Should be corrected, but abatement documentation not required o Regulatory o Other findings and recommendations Closing Conference o Review findings o Due dates o Methods of abatement o Interim protection o Follow up visits o Training visits o Offer formal training After the Visit o Written report • Recommendations on correcting and improving safety and health program. o Explaining the findings o Confirming abatement periods After the Visit o Follow-up visits available o Other assistance available o OSHA requires hazard abatement of all serious hazards o If not abated, referral to federal OSHA for potential enforcement action is possible On-Site Consultants Will: o Suggest general approaches or options for solving a safety or health problem; o Identify kinds of help available, if needed; o Help recognize hazards in the workplace; o Provide a written report summarizing findings. On-Site Consultants Will: o Assist in developing or maintaining an effective safety and health program ; o Provide awareness training and education for employees . On-Site Consultants Will Not: o Issue citations or propose penalties for violations of OSHA standards; o Routinely report possible violations to OSHA enforcement staff; o Guarantee that your workplace will “pass" an OSHA inspection. Exemptions and Deferrals o SHARP (Safety and Health Achievement Recognition Program) exemption o Pre-SHARP inspection deferral o SST deferral Safety and Health Achievement Recognition Program (SHARP) o Parallels Federal OSHA’s Voluntary Protection Program (VPP) o A company must work on an on-going basis with the OSHA On-Site Consultation Program and demonstrate an exemplary safety and health program. o Provides an exemption from general schedule inspections Pre-SHARP Inspection Deferral o Companies that are working toward SHARP status but are not quite ready o One time o Up to 18 months o Action plan Site Specific Targeting (SST) Deferral o Must request and schedule a full service visit, safety and health o Deferral lasts 90 days from the date that the visit is actually requested. o Requires notification to OSHA that the employer has a visit scheduled o Cannot be extended beyond 90 days o List changes year to year Myths About the OSHA On-Site Consultation Program o The Program routinely notifies OSHA to conduct a compliance inspection. o Federal OSHA knows which companies have used On-Site Consultation Program services. o Abatement of serious hazards are not required. o We provide site-specific training to employers. Why Bother? To Get Started: o Phone Call • 800-282-1425 – State Wide (Automated) • 614-644-2631 o E-mail • OSHAOn-SiteRequest@BWC.State.OH.US