OSHA UPDATE PANEL
Monday, October 3, 2011
Kevin Kilp, Area Director, Harrisburg
Jean Kulp, Area Director, Allentown
Mark Stelmack, Area Director, Wilkes-Barre
Rev:30 Sept 2011
Overall Agenda:
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Inspection Targeting
Regulatory Agenda
Updates
Website Tools
Where Do I go for help
Questions and Answers
REGION III
Regional Administrator:
Deputy Regional Administrator: Kurt Petermeyer
Pennsylvania OSHA Area Directors
Mark Stelmack
Theresa Naim
Jean Kulp
Kevin Kilp
Albert D'Imperio
Robert Szymanski
Rev: 14 Aug 2008
How Does OSHA Decide Who to
Inspect?
OSHA cannot inspect all workplaces it covers
each year. The agency seeks to focus its
inspection resources on the most hazardous
workplaces.
DIRECTIVE NUMBER: CPL 02-00-148
http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-00-148.pdf
OSHA INSPECTIONS
Inspection/Investigation Types
Inspection Priorities:
• Unprogrammed inspections:
– Imminent Danger
– Catastrophes and Fatal Accidents
– Complaints and Referrals
– Follow-up Inspections
OSHA INSPECTIONS
Inspection/Investigation Types
Inspection Priorities:
• Programmed Inspections:
– Site-Specific Targeting (SST),
– Construction
– Scheduling for Maritime Inspections
– Special Emphasis Programs (SEPs).
– National Emphasis Programs (NEP),
– Regional (REP) & Local Emphasis Programs
(LEP),
– Other Special Programs.
Site-Specific
Targeting 2011
(SST-11)
DIRECTIVE NUMBER:
11-03 (CPL 02)
EFFECTIVE DATE:
September 9, 2011
http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-11-03.pdf
Sept 2011
http://www.osha.gov/pls/oshaweb/owadisp.show_document
?p_table=NEWS_RELEASES&p_id=20646
OSHA INSPECTIONS
(SST-11)
• Site Specific Targeting (SST)
• Comprehensive
• 3 Categories:
– Manufacturing Establishments
– Non-Manufacturing Establishments
– Nursing and Personal Care Facilities
• Based upon DART and DAFWII Rates
OSHA INSPECTIONS
Site Specific Targeting (SST-11)
Primary
Secondary
Tertiary
DART
7.0
5.0
OSA
DAFWII
5.0
4.0
Discretion
DART
15.0
5.0
OSA
DAFWII
14.0
4.0
Discretion
DART
16.0
13.0
OSA
DAFWII
13.0
11.0
Discretion
Manufacturing
Establishments:
Non-manufacturing
Establishments:
Nursing and Personal
Care Facilities (805)
Injury and Illness
Recordkeeping
National Emphasis
Program
(RK NEP)
DIRECTIVE NUMBER:
10-07 (CPL 02)
EFFECTIVE DATE:
September 28, 2010
EXPIRES:
February 19, 2012
http://www.osha.gov/OshDoc/Directive_pdf/CPL_02_10-07.pdf
https://www.osha.gov/pls/oshaweb/owadisp.show_document?
p_table=NEWS_RELEASES&p_id=16725
Appendix A
Verification of each Recordable
Injury and Illness Record
Onsite inspection to review CY 2008 and CY 2009 injury and
illness records:
• Medical records
• Worker’s compensation records
• Insurance records
• Payroll absentee records
• Company safety incident reports
• Company first-aid logs
• Alternate duty rosters
• Disciplinary records pertaining to injuries and illnesses.
Note: This includes records stored on and off site.
Example Recordkeeping Citations
Failure to :
• record injuries or illnesses on the OSHA 300 form.
• record a case correctly
• adequately describe the location
• provide a specific description
• enter the correct number of calendar days
• not completing or not accurately completing the OSHA
301
• complete an OSHA 300A.
• provide copies of records
• …
http://www.claimsjournal.com/news/midwest/2010/05/03/109492.htm
Company fined $182,000 for failing to record worker
injuries and illnesses
OSHA issued eight citations to Company Inc. and fined the
company $182,000 for failing to document and report worker
injuries and illnesses at its distribution center. OSHA inspectors
found that Company had willfully disregarded its responsibilities
to comply with OSHA regulations by continuously failing to
correctly classify worker injuries or illnesses and not correctly
recording the number of days a worker was away from work due
to injury or illness. Additional recordkeeping violations found by
inspectors included two for which the company had been cited
previously. See the for more information on the failure of
Company to report worker injuries.
Apart from this particular investigation, OSHA has implemented a
NEP to assess the accuracy of information on workplace injuries
and illnesses recorded by employers.
http://www.osha.gov/pls/oshaweb/owadisp.show_docu
ment?p_table=NEWS_RELEASES&p_id=18261
OSHA INSPECTIONS
National Emphasis Programs (NEP)
Sept 2011
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Combustible Dust
Federal Agencies (includes FAA)
Flavoring Chemicals (Diacetyl)
Amputations (Hazardous Machinery)
Hexavalent Chromium
Lead
Primary Metals
PSM Covered Chemical Facilities
Petroleum Refinery Process Safety Management
Injury and Illness Recordkeeping
Shipbreaking
Crystalline Silica (follow-ups)
Trenching and Excavation
http://www.osha.gov/dsg/combustibledust/index.html
National Emphasis
Program (NEP) on
Hexavalent
Chromium
http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-02-076.pdf
OSHA Directive CPL 02-02-076, Feb. 23, 2010
OSHA compliance assistance resources:
What is Hexavalent Chromium?
• Toxic form of chromium metal that is
generally man-made
• Used in many industrial applications
primarily for its anti-corrosive
properties
• Can be created during certain “hot”
work processes where the original form
of chromium was not hexavalent
Sept 2011
Sept 2011