the bwc division of safety & hygiene’s osha on-site consultation program

The BWC Division of Safety & Hygiene’s

OSHA On-Site Consultation Program

OSHA On-Site Program Overview

o 90% federally funded

o 10% state funded - Ohio Bureau of Worker’s Compensation

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.

Industrial Hygiene Serviceso Conduct noise surveyso Conduct air monitoringo Ventilation assessmentso Provide advice as to the proper industrial

hygiene/engineering controls

OSHA On-Site Consultationo 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 Reviewo 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 Identifiedo 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 Regulatoryo Other findings and recommendations

Closing Conference

o Review findingso Due dateso Methods of abatemento Interim protectiono Follow up visitso Training visitso 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 availableo Other assistance availableo 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 Deferralso SHARP (Safety and Health Achievement

Recognition Program) exemptiono Pre-SHARP inspection deferralo 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 Deferralo Companies that are working toward SHARP

status but are not quite readyo One timeo Up to 18 monthso Action plan

Site Specific Targeting (SST) Deferralo Must request and schedule a full service

visit, safety and healtho Deferral lasts 90 days from the date that the

visit is actually requested.o Requires notification to OSHA that the

employer has a visit scheduledo Cannot be extended beyond 90 dayso List changes year to year

Myths About the OSHA On-Site Consultation Programo 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