There are so many businesses and establishments with safety issues that OSHA can’t possibly inspect them all in a given year. Just how do they choose where to go? Obviously, if your facility has had some significant safety issues recently, OSHA will be paying attention. But what else will bring them knocking? How do they parse through the data they receive to decide where their limited resources should be spent? Your site could be targeted for inspection through a number of different programs.
There are several programs that OSHA uses to target facilities for inspections. Sometimes a facility might be chosen for inspection through more than one of these programs. In those situations, OSHA either completes the inspections for each program in one visit or more than one visit is made. Below is a brief description of these programs.
OSHA’s Strategic Plan has goals to reduce fatalities, injuries and illness. In 2003 they identified 7 industries where there was the most risk and focus their resources here. This is a five year plan, so OSHA will be updating this next year.
Landscaping and Horticultural Services
Oil and Gas Field Services
Fruit and Vegetable Processing
Blast Furnace and Basic Steel Products
Ship and Boat Building and Repair
Public Warehousing and Storage
Concrete and Concrete Products
One aspect of focusing on industries, is to focus on specific hazards in those industries. OSHA has National Emphasis Programs to focus on specific hazards. One recent example is a focus on highly hazardous chemicals in the petroleum industry. Others include amputations, lead, silica, shipbuilding and trenching/excavations.
In addition, OSHA has a Local Emphasis Program. Regional and area offices identify areas of concern in their region and focus their resources there. In some cases, the emphasis is on a specific area in one of the 7 industries listed above. Other times, it is a focus on a local industry or safety hazard. Below are some examples of Local Emphasis Programs in Regions II and III. For a complete list and the cities where there is an emphasis, check out OSHA’s website (OSHA’s Local Emphasis Program). Construction/ Demolition including worksites and fall hazards. Also a focus on highways, bridges and residential in some areas.
Warehouse and Refuse Handlers and Haulers
Bloodborne Pathogens – Philadelphia, Pittsburgh, Allentown, Erie
Concrete Block and Brick – Harrisburg, Philadelphia, Pittsburgh, Erie
Dust Explosions – Harrisburg, Wilkes-Barre, Wilmington
Never Before Inspected High Hazard Manufacturing – Allentown, Harrisburg
Shipbuilding – Philadelphia
Silica in Cut Stone – Allentown
Another program that is used to prioritize inspections is the Site Specific Targeting Program. Each year data is gathered through the OSHA Data Initiative Survey (sent to non construction establishments with 40 or more employees, typically to higher risk industries). Workplaces with the highest rate of injuries and illnesses are targeted for inspection. A little over 50% of the workplaces who received this survey are inspected the following year. If your establishment has a particularly high DART or DAFWII rates (11.0 & 9.0 respectively) or abnormally low for your industry, you are very likely to be inspected.
As with the EPA, it is just as important to have a strong relationship with OSHA inspectors, through open communication and prompt response. In fact, OSHA has programs for companies they see as good apples and for those that have gone sour:
Cooperative Programs: There are several programs that your company can participate in that could result in a deferral or no inspections for a given year. These include OSHA Strategic Partnership, OSHA On-Site Consultation Program 90-Day Deferral, Voluntary Protection Programs (VPP) and SHARP. Each type of program has a slightly different focus: small businesses, trade organizations, etc.
Enhanced Enforcement Program: Companies who repeatedly ignore requirements and where OSHA feels the employees are at risk are put into this program. They identified 467 companies in 2006. These companies will be inspected more often, even at their facilities which weren’t the initial cause of the violations. They will also likely receive tough penalties.
Ensuring compliance can be a challenge, particularly if your safety department is understaffed. Environmental and Engineering Solutions has experience completing audits of facilities for a variety of regulations, developing compliance systems, air sampling and more. Feel free to contact us with your safety and industrial hygiene needs.
Related Links: OSHA’s enforcement report for 2006 National Emphasis Program to eliminate highly hazardous chemicals in the petrochemical industry (for other NEPs, go to OSHA’s main page and click on Directives) OSHA’s Local Emphasis Program Site Specific Targeting Program 2007
Number 40 part 2