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Back to Basics is a weekly feature that focuses on important but possibly overlooked information that any EHS professional should know. This week, we will study OSHA's key plans.

How likely is it that you see a compliance safety and health officer (CSHO) appearing in your workplace to be inspected by the Occupational Safety and Health Administration (OSHA)?

The agency has several methods for allocating law enforcement resources. For example, the agency’s initial response to an employee’s complaint may be a letter or phone call rather than an on-site inspection. The agency also uses the OSHA Weighting System (OWS) to evaluate the performance of its regional offices.

OWS has assigned multiple law enforcement units (EU) for different types of inspections. The agency allocates the largest number of EUs for inspections involving criminal or major cases: seven EUs. It grants five EUs for process safety management (PSM) inspections of high-risk chemicals and inspections after death or disasters.

The weighting system grants three EUs to check the agency’s “big four” hazards: trapped or in the middle, electrical, falling, and shock hazards. OSHA designates two EUs to examine certain hazards, including ergonomics (musculoskeletal diseases), confined space hazards requiring permits, occupational noise, location-specific targets (based on injury and illness data submitted by employers), and workplace violence. All other inspections get an EU.

OSHA also uses national, regional, and local priority programs (NEP, REP, and LEP) to focus its law enforcement resources on specific hazardous or high-risk industries. The agency’s latest NEP is a focused plan for COVID-19. It was launched on March 12 and revised on July 7, with minor changes made on August 30.

The district office starts their NEP enforcement work from the site selection and generates a general list of agencies that may be inspected. Agency directives for specific hazards NEP usually include a list of target industries.

The main targets of the COVID-19 NEP include ambulances and home healthcare services; correctional facilities; healthcare and long-term care facilities; hospitals and doctor offices; department stores, grocery stores, supermarkets, restaurants, meat packaging and poultry processing facilities, and Warehouse and storage facilities.

Because healthcare and healthcare support services are subject to the OSHA Emergency Temporary Standards (ETS) for COVID-19, inspections of these workplaces include a review of the employer's written COVID-19 plan.

In non-healthcare workplaces, if the employer fails to implement hazard control because all employees are vaccinated, CSHO must verify the employer's statement. CSHO will then review the injury and disease logs for active COVID-19 infections or infections that caused lost working hours.

On September 20, OSHA announced plans to develop a NEP for heat stress and develop heat stress rules as part of a multi-agency effort to address climate hazards, including overheating.

The agency stated that the new economic policy may model the REP that the agency has already implemented in Arkansas, Louisiana, Oklahoma, New Mexico, and Texas (District 6), with a focus on outdoor workers. Of fever-heat cramps, heat stroke and heat stroke. .

The heatstroke check is triggered on days when the high temperature index of the Meteorological Bureau is expected to exceed 80 degrees, focusing on preventive measures to prevent and deal with high temperature-related diseases.

NEP is a temporary plan, but OSHA's earliest crystalline silica and lead plan was released in 2008. The agency’s current NEP includes:

Amputation in manufacturing NEP focuses on preventing amputation by checking for violations of OSHA's manual and portable power tools, lockout/tagout (control of hazardous energy), and machine protection standards.

Industries covered include concrete manufacturing; food manufacturing; machinery manufacturing; non-metallic mineral product manufacturing; paper, pulp and wood manufacturing; primary metal and metal product manufacturing; and plastic manufacturing, as well as furniture and vehicle manufacturing.

Inspection procedures include the opening meeting, the review of accident reports and injury and illness records, as well as workers’ exposure to the danger of amputation caused by machinery and tools in the workplace.

The combustible dust NEP was reissued in 2008, canceling the NEP issued in 2007, and covers the inspection of dust that may cause deflagration, other fires or explosions, including:

In view of the wide variety of combustible dust, NEP covers a wide range of industries, including power generation, transmission and distribution industries; food and agricultural products processing; and pharmaceutical preparations. It also includes the manufacture of various metals and woods, as well as the production of missiles and spacecraft.

NEP's inspection procedures include CSHO standards for identifying and characterizing combustible dust hazards. CSHO must pay attention to dust collectors, piping works and dust collection containers.

The hexavalent chromium NEP is a program for specific hazards that focuses on checking for violations of OSHA's general industrial, construction and marine hexavalent chromium standards. The target industries of NEP include aircraft manufacturing; shipbuilding and repair and shipbuilding and repair; ferrous metal foundries and steel plants, and secondary smelting, refining and alloying of non-ferrous metals; chrome and other inorganic pigments, inorganic dyes and pigments, industrial Inorganic chemical manufacturing; metal plating and finishing (plating, electroplating, polishing, anodizing and coloring); and plastic materials and resin manufacturing.

Inspection procedures include an opening meeting, evaluation of the employer’s industrial hygiene plan, and sampling procedures for measuring workers’ exposure to toxic substances during inspections.

The lead NEP issued in 2008 focused on inspections for violations of OSHA lead standards for general industry, construction, and shipyards. NEP’s target facilities include shooting ranges, heavy and residential buildings, paint and paper suspension, and car repair; battery, bus, and truck manufacturing; and copper, glass, and paint manufacturing.

Inspection procedures include reviewing the employer’s hazard communication plan and medical supervision plan to lead and evaluate engineering controls and personal protective equipment (PPE) during facility or site inspections, as well as to evaluate the employer’s housekeeping and respiratory protection plans.

CSHO will also conduct personal air monitoring and collect wipe samples. CSHO must decide whether to use the employer's monitoring data to assess the employee's risk. If notified of other workplace hazards or violations, civil society security organizations can also expand the scope of inspections.

Industry-specific NEPs for primary metal manufacturing focus on chemical and physical hazards in aluminum, copper, and steel manufacturing. The inspection focuses on compliance with hazard notification and respiratory protection standards, which may include inspection procedures under NEP for lead and respirable crystalline silica.

The inspection procedures include evaluating the availability and quality of the hazard communication plan, safety data sheets (SDS), and how employers’ hazard assessments guide the selection and use of personal protective equipment and respiratory protective equipment.

In addition to the SDS review, inspections can also include whole-class personal air monitoring and/or short-term personal air monitoring to determine the level of exposure to hazardous substances.

Checks under NEP are not always programmed. During a recent inspection of an amputee foundry in northern Wisconsin, agency inspectors conducted a second inspection based on the agency’s main metal industry NEP and found that it was related to exposure to respirable crystalline silica and excessive occupational noise. Irregularities. During the NEP inspection, the employer reported another injury to the inspector, leading to a third inspection.

The chemical facility NEP ensures compliance with the agency's PSM standards for high-risk chemicals. The facilities covered include oil refineries, as well as facilities for chemical manufacturing and the production of explosives and fireworks.

The inspection procedure emphasizes inspections of PSM rather than documents; the agency has a list of "dynamic issues" used by civil society organizations, but it has not been made public. The agency argued that the facility may have an extensive written PSM plan, but lacked sufficient plans to implement it. CSHO will inspect the host and contract employer of the facility.

The silica NEP revised in 2020 covers the implementation of the construction, general and maritime industry standards for respirable crystalline silica. The revised NEP solves the implementation problem of the 2016 revised standard.

The elements of the revised NEP include:

Target industries include support activities for the oil and gas business; power generation, transmission and distribution; and dozens of manufacturing industries. Inspection procedures include air sampling for exposure monitoring, observation of other hazards, and informing workers of their whistleblower protection rights.

Industry-specific NEPs used for shipbreaking or shipbreaking; recycling their raw materials; and a shipbreaking order was issued in 2016 to address the high incidence of injuries and diseases in shipbreaking operations. NEP complies with the obligations of the Department of Labor under the Memorandum of Understanding (MOA) with the Department of Defense, the Department of Transportation, and the EPA on the coordination and information sharing of domestic shipbreaking operations. The inspection focuses on hazards, including exposure to asbestos, lead, and polychlorinated biphenyls (PCB), as well as removal of bilge and ballast water, confined spaces, ladders and scaffolding, metal cutting, occupational noise, oil or fuel removal, and tank cleaning , Paint removal, power industrial trucks and walking surfaces.

The EPA, OSHA, and U.S. Navy inspection procedures are detailed in the MOA.

Trenching and excavation NEP's focus is to implement the agency's construction industry excavation standards. CSHO can initiate NEP inspections at any time when open ditches or excavations are observed during other inspections or during normal workday travel. Even if the agency’s regional office cannot be contacted because there is no mobile phone or landline service, they can still perform an inspection.

Inspections are usually limited to assessing workers’ exposure to safety and health hazards associated with excavation, but if other hazards are “obvious”, they may be expanded.

Factors that affect your acceptance of OSHA inspections include complaints; targeting specific locations due to the high incidence of injuries and illnesses in your annual summary (form 300A); hazards highlighted in the agency’s OWS; and national, regional, or local priority plans .

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