PRESENTED BY:
Keven L. Yarbrough
Assistant Area Director
Tampa Area Office 813-626-1177
OSHA OFFICES IN FLORIDA
TAMPA AREA OFICE
CURRENT
• SAFETY SPECIALISTS
• INDUSTRIAL HYGIENISTS
• COMPLIANCE ASSISTANCE
SPECIALIST
• WB INVESTIGATORS
• ADMINISTRATIVE SUPPORT
• ASSISTANT AREA DIRECTOR
• AREA DIRECTOR
• TOTAL
19
7
1
3
4
3
1
38
Surviving OSHA Inspections
Hello:
I'm from OSHA and I'm here to help?
OK, you can come in.
WHY DO EMPLOYERS FEAR
OSHA INSPECTIONS?
 Uncertainty
 Time
 Citations and Penalties
 Damage to Company Reputation
 Loss of Future Business
 Legal Fees
 OSHA rumors and Fear
(OSHA WILL SHUT YOU DOWN?)
As a result of this presentation YOU will:
• Receive the Truth about OSHA Inspections.
• Be able to converse with the CSHO in his
language … on your terms.
• Be able to Conduct OSHA type inspections in
Your facility.
• Receive more information about OSHA’s
inspection process in one day than most
safety professionals receive in a year!
THE INSPECTION PROCESS
 THE OPENING CONFERENCE.
 THE INSPECTION TOUR.
The anatomy of an OSHA violation.
i. Hazard; ii. Standard; iii Exposure
and iv. Knowledge.
 THE CLOSING CONFERENCE.
 THE INFORMAL CONFERENCE.
CSHO Preparation
The Compliance officer will:
Review Company History.
Determine the scope of the Inspection:
a. Comprehensive Insp. = A Complete “wall to wall”
i.e. General Schedule, SST and Dodge Reports.
b. Partial Insp. = Limited to Hazardous Areas,
Operations, Conditions or Practices at the establishment i.e.
NATIONAL – REGINAL AND LOCAL EMPHISES
PROGRAMS. NEP, REP AND LEP’s, Complaint and Referral
Inspections.
The Opening
Conference
• The CSHO will: Always Present Credentials!!!!!!!!
• Inform employer of the purpose of the inspection.
• Conduct Opening Conference with Employer and
Employee Representative.
• CSHO will outline general terms the scope of
inspection to include the need for privet employee
interviews, ER rights during the inspection, the
walkaround and the closing conference.
The Opening
Conference cont.
• The CSHO will:
• Inform employer of the use of video/Audio
recorder may be used.
• Explain the advantages of immediate abatement
i.e. no abatement certification requirements for
violations quickly corrected during the inspection.
• CSHO’s will review OSHA programs and records
such as HazCom, LOTO, PPE and other programs
as necessary.
The Walkaround Inspection.
• Purpose: to identify potential safety and/or health
hazards in the workplace.
• CSHO may be accompanied by the employer,
employee representative.
• Safety and health violations will be brought to the
attention of the employer and employee
representative at the time they are documented.
The Walkaround Inspection
•
•
•
•
•
CSHO will Record:
The Identity of the exposed employee(s)
The hazard the employee is exposed to
The proximity to the hazard
The employer’s knowledge of the condition, how
long the condition existed and the manner
measurements were taken
The Walkaround Inspection
• Sampling: the CSHO will:
• Determine whether sampling such as but not
limited to, air sampling and or surface sampling is
required.
• Photographs and/or videotapes shell be taken
whenever CSHO’s determine there is a need.
• Confidential or trade secret information will be
identified as such and kept separate from other
evidence.
The Walkaround Inspection
• If the CSHO observes violations of laws enforced
by other government agencies, such cases will be
referred t the appropriate agency.
The Closing Conference
• At the end of the inspection the CSHO will
conduct a Closing Conference with Employer and
Labor representatives.
• The Closing Conference may be held on-site or by
telephone as deemed appropriate.
• CSHO shell discuss apparent violations and other
pertinent issues found during the inspection.
The Closing Conference
•CSHO will give employers the publication, “Employer Rights
and Responsibilities Following an OSHA inspection.
•CSHO will advise attendees that a request for an informal
conference with the Area Director is encouraged.
– Resolve disputed citations and penalties without need
for litigation.
– Discuss ways to correct violations;
– Discuss proposed abatement dates;
– Discuss available OSHA programs.
– 15 day contest period.
What Do We Have Here…Prove It!
What the Supervisor Expects
The anatomy of violation
i. Hazard; There must be a hazardous
condition.
i. Standard; Does a standard apply?
ii. Exposure: Employee exposure and;
iii. Employer Knowledge.
THE INSPECTION PROCESS
 THE OPENING CONFERENCE.
 THE INSPECTION TOUR.
The anatomy of an OSHA violation.
i. Hazard; ii. Standard; iii Exposure
and iv. Knowledge.
 THE CLOSING CONFERENCE.
 THE INFORMAL CONFERENCE.
The Question?
The End
PRESENTED BY:
Keven L. Yarbrough
Assistant Area Director
Tampa Area Office 813-626-1177