Be Prepared For A Cal/OSHA Inspection
By Judy Kerry
State Compensation Insurance Fund

Cal/OSHA inspectors make unannounced visits to ensure California workplaces are safe and healthy. If your facility has documented uncontrolled hazards and receives citations, the penalties, legal issues, and lowered employee morale and publicity can cause serious financial and business impacts. Managers, supervisors, and employees need to know what to expect during a Cal/OSHA inspection and how to respond appropriately.

Cal/OSHA conducts site inspections in cases of imminent danger or industrial accidents. A fatal injury to one or more employees; a serious injury or illness; a serious exposure; or the inpatient hospitalization, regardless of duration, of three (3) or more employees (a catastrophe) will trigger an inspection and must be reported to Cal/OSHA within 8 hours. Inspectors also focus on high-hazard work sites and industries with loss rates at or above Bureau of Labor Statistics averages.

Inspectors will also visit worksites as a response to employee complaints posing an imminent danger. At times, employee complaints may be considered low risk. These are handled with a letter reporting general information and a request to follow-up and report back within a certain time period. Conduct investigations into these complaints, gather documentation, and submit it in writing on time to the Cal/OSHA office. Note that the name of the complaining employee will be kept confidential. It is against the law to retaliate against employees for reporting safety hazards and concerns.

Cal/OSHA inspectors will present their identification and request permission from a management representative to conduct a site inspection. Instruct your receptionist and/or security personnel on which management staff should be notified of a visit. Inspectors will wait on site about one hour for management contact. They will conduct an opening conference to explain the reason for the visit. Inspection walkthroughs may include your entire facility, or a targeted work area. Inspectors have the right to walk around the building (accompanied), interview employees in private, and document hazards with photos and measurements.

When you work with an inspector, be courteous and friendly. Limit the inspection focus to only the documents and facility areas listed in the opening conference. Accompany the inspector at all times, though private employee interviews can be arranged in controlled access conference rooms. Provide neutral, fact-based answers to the inspector’s questions; don’t offer opinions or guess at answers. It is okay to offer follow-up at a later date. Don’t argue with an inspector. Also, don’t agree with comments as they may be incorrect. Don’t make jokes about health and safety, worksite, or personnel matters. Keep notes, photos, and records during the visit. If the inspector takes measurements or readings, you should conduct the same measurements and readings simultaneously.

After the walkthrough, the inspector should conduct a closing conference to provide inspection results, next steps, and timelines. Inspectors may request protocols, work procedures, or other documents. Deadlines for submittal range between 24 hours and 14 days. The Injury and Illness Prevention Program (IIPP) may be required immediately, since it is required to be readily accessible to employees. Conduct follow-up investigations, corrective actions, and gather requested documents and provide them to the inspector by the stated deadline. Missed deadlines can result in further site inspections or citations.

Cal/OSHA inspections are unannounced. Start planning now so you can present a competent, organized, and compliant response to a Cal/OSHA inspection. Designate and train staff to respond to Cal/OSHA inspectors. Maintain your safety programs and employee training procedures at appropriate levels. Keep safety records organized and on site and ensure key staff know how to access them. ?

Source: Cal/OSHA website: http://www.dir.ca.gov/DOSHPol/P&PC-1A.HTM

Improve Your Safety Effectiveness

By Judy Kerry
State Compensation Insurance Fund

Want to increase your company’s safety effectiveness? There are some simple things you can do so that workers will care about working safely and following proper work procedures to reduce the frequency and severity of workplace injuries and illnesses.

First of all, it’s important to stress safety training and instill hazard awareness early. Emphasize accident prevention during any job training. Explain rules and regulations thoroughly. Rules are less likely to be broken or ignored when workers understand them and why they have been established. Generalized statements about working safely are not very helpful. Be specific. Then, enforce safety rules uniformly. You can’t let one worker break the rules then expect others to follow them.

Communicate frequently. Talk with workers about safety. Encourage two way conversations. Few people like to be told dogmatically what they should or should not do, so try to avoid lecturing or preaching. If workers have ideas that will improve safety performance, listen to them. If an idea is practical put it into effect and make certain the worker gets credit for it.

Most employees want recognition, so be a credit giver. Observe how workers do their job. When safe work practices are followed, let them know you are aware and pleased. Praise correct procedures and make workers aware of areas that need improvement.

Be a hazard detector. It’s human for workers who have done a job over and over to take work operations for granted. However, a relaxed attitude can lead to accidents. Watch for changing worker behavior. If you notice that a usually reliable worker has become inattentive or preoccupied, it’s a danger signal. When a worker’s mind is not on the job, the stage is set for an accident. Train workers to always be safety conscious, so that they are continuously aware of injury hazards to themselves or their co-workers.

Analyze jobs from a safety viewpoint. Know each job in your operation so you can spot potential hazards. If a different work practice will eliminate a hazard, introduce it. Explain why, from a safety viewpoint, certain work practices must be followed, without exception. And finally, be aware of the physical or emotional condition of your workers to determine if they are able to do their jobs safely. You may want to reassign workers to activities they can perform without jeopardizing their safety or the safety of others.

Communicate Workplace Hazards

By Judy Kerry
State Compensation Insurance Fund

Every day many California employees work with or are incidentally exposed to hazardous substances that can harm their health or cause other safety hazards. Whatever the size of the facility or the number of hazardous substances, it’s essential that both employers and employees know how to identify any potentially hazardous substances, understand the health hazards associated with the substances, and follow safe work practices.

Cal/OSHA has a hazard communication standard that requires every workplace which has or uses hazardous substances to have a written and effectively implemented Hazard Communication Program that specifically addresses the potential hazards found at that particular site. And, the program must be accessible to employees (or their representatives) and to Cal/OSHA. 

The written hazard communication (HazCom) program must name the individuals responsible for implementing, maintaining, and periodically reviewing the program and the procedures for meeting all the requirements of the standard. Specifically, the workplace HazCom program must include:

• A list of all hazardous substances in the workplace - The list may be compiled for the workplace as a whole or for individual work areas and can serve as a checklist to ensure that all hazardous substances in the workplace have Material Safety Data Sheets (MSDSs) and labels.
• A completed MSDS for each hazardous material listed/used in the workplace - The MSDS contains useful information on the nature of the hazards and how to use, store, and dispose of the material. It also describes what protective measures to take while using the material and what first aid measures to follow if an exposure to the substance occurs. MSDSs must contain all of the sections required by the standard and be readily available to employees.
• Methods for employee training and awareness - Employees must receive training on the HazCom program requirements including its location and availability; the identification and location of hazardous substances; and how to read and understand MSDSs. Training should include how to read and understand label information including physical and health hazards of the substance; how to detect the presence or release of the substance; and what precautionary measures needed to protect themselves from hazards during normal use and in emergency conditions. Training must be done at the time of initial work assignment or when a new material is introduced. Training must be appropriate in content and vocabulary for the education, literacy, and language comprehension level of the employee(s).
• Labels and hazard warning information - Employers are required to use legible labels and other forms of warning to clearly and quickly communicate what’s in a container, its hazards, the safety precautions, and the name and address of the manufacturer. Labels and other forms of warning are to be conspicuously placed on containers so that the message is readily visible. Labels should not be removed and if torn or defaced, they must be replaced.

Employers who tailor their written program to meet the specific needs of their workplace will maximize the benefits of workplace safety.

To access a downloadable copy of Cal/OSHA’s Guide to the California Hazard Communication Regulation, visit its website at www.dir.ca.gov/dosh/dosh_publications/hazcom.pdf

For more detailed information about the HazCom standard including its exceptions; refer directly to the California Code of Regulations Title 8 or the Labor Code.

Conduct a Site Safety Inspection

by Judy Kerry
State Compensation Insurance Fund

Regular safety inspections using site-specific checklists help to keep workers safe by identifying and correcting hazards in the workplace before they can cause an illness or result in an injury. How often you conduct a site inspection depends on the workplace and its hazards. Some sites may need checks at every shift and others may need daily, quarterly or annual inspections. After any inspection, make sure you remember to document the observations, identified hazards, and corrective action.

At least annually, review your administrative records and postings at your workplace. Check to see that safety programs, procedures, trainings, MSDS binders, and other records are up to date and accurate. Employer postings required by Cal/OSHA, Workers Compensation, and labor law must be placed where they are “likely to be seen” by employees. And, all critical procedures (e.g. spill cleanup, evacuation, etc.) should be posted in prominent locations for employees to quickly reference in an emergency.

Notice if workers consistently practice good housekeeping – which is critical to a safe work environment. Are chemicals being stored within their compatible classes and are flammables being kept in a secured flammable cabinet? Are exits clear of stacked material and other impediments? Check to see that items and debris are kept up off floors and out of walkways and that stored items are stacked properly on shelving units firmly attached to the wall; heavier items should be on the bottom, lighter items stored on top shelves. Limit the height of stacked materials to ensure that they are stable and self-supporting. Items stored on tops shelves require 18” clearance from fire sprinkler systems and electric panels should have 36” clearance in front.

Inspect floor surfaces to assure they are clean and free of slip hazards such as dirt, granular substances, equipment parts, water, or oil. Wet surfaces should be covered with non-slip materials and holes in the floor, sidewalk, carpet, or other walking surface should be repaired properly, covered, or made safe. Ground Fault Circuit Interrupter (GFCI) outlets should be installed around wet areas.

Check the condition of equipment and tools to assure they’re in good working order. Take out of service or tag defective equipment. Examine power cords to determine if they are intact, need repair, or should be replaced. Extension cords should not cross walkways and should be used only temporarily. Install additional power outlets if extension cords are necessary on a permanent basis or there are “daisy chained” power strips. Check that equipment guards and protective coverings are in place. Is the personal protective equipment clean and accessible with available areas and materials for decontamination and storage?

Test your safety and emergency systems and equipment such as fire alarms and sprinkler systems annually and assure that your fire extinguishers are charged monthly and recharged annually. Periodically inspect all first aid kits and replenish or replace supplies when needed. Ensure areas under desks and tables are accessible to allow proper ergonomic seating and access in case of an earthquake. Aisles and walkways need 36” clearance in an office and 44” in a shipping area. Emergency exits should be clearly marked so they can be seen from any point in the facility. Label doors that are not exits to avoid confusion. Fire doors should not be propped open.

Finally, encourage workers to make daily site and equipment safety inspections and to correct or report observed hazards. ?

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- Get Your Workers Back in Control

Jokes about nagging back pain get standup comedians a lot of laughs, but back strains and sprains are not at all funny, nor should they be an unavoidable curse to anyone.

Back injuries suffered in California’s workplaces last year ran up a bill of millions of dollars. Those disabling back injuries were no laughing matter for the workers who lost time from work or from their personal activities. The sad truth is that most of the pain and lost time could have been prevented if workers had been more aware of how their backs function and how to safely lift bulky or heavy loads.

The back is a network of fragile ligaments, discs, and muscles which can easily be thrown out of order. The back’s complex design breaks down when it is forced to perform activities it was not designed to do.

One sure way to risk injuring the back is to lift heavy or bulky loads improperly or unassisted. The unsupported back cannot operate like a derrick or a crane boom. Lifting with the back twisted or bent just begs for a pulled muscle or ruptured disc. The back can be damaged quickly but can take a long time to heal. So workers should be encouraged to do their lifting with good sense and a little extra help from a co-worker or mechanical aid.

Workers should learn to squat over the item to be lifted, and face it squarely. In this position, the back gets added lifting strength and power from the legs and arms. Teach workers to tilt the item on edge with its long axis straight up so the the center of the weight is as high as possible above the ground. Next, the worker should move up close to the item, because the backbone must act as a supporting column, and it takes the least strain close in. In this position, the worker is ready to lift. Still squatting, the feet should be set with legs pointed right at the load, with the back straightened, the worker may then grasp the load with both arms and slowly stand up with it.

A good way to help workers learn the right from the wrong way to lift, is to have them practice lifting correctly a few times. They will notice that the correct way to lift is the easiest way to lift the load, with the least strain and awkwardness. To lift the wrong way will, over time, cause injury and pain and then no one will be laughing.

En Español

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The above evaluations and/or recommendations are for general guidance only and should not be relied upon for legal compliance purposes. They are based solely on the information provided to us and relate only to those conditions specifically discussed. We do not make any warranty, expressed or implied, that your workplace is safe or healthful or that it complies with all laws, regulations or standards.

Plan for Workplace Emergencies

All California businesses with more than ten employees must maintain a written Emergency Action Plan. Title 8 CCR 3220, Emergency Action Plan, states that the Emergency Action Plan "shall cover those designated actions employers and employees must take to ensure employee safety from fire and other emergencies. For those employers with 10 or fewer employees the plan may be communicated orally to employees and the employer need not maintain a written plan."

Planning
In an emergency, the effectiveness of response depends on advanced planning and training. Management's commitment and employee involvement are essential to the action plan. The emergency response plan should cover all potential emergencies that could be expected at the work site. The written emergency action plan must be kept at the workplace and made available for employees to review. It should be reevaluated and updated periodically. The following elements, at a minimum, must be included in the plan:

• Emergency escape procedures and mapped escape routes
• Procedures to be followed by employees who remain to operate critical operations before they evacuate
• Procedures to account for all employees after evacuation
• Rescue and medical duties for employees who perform them
• Means for reporting fires and other emergencies
• Persons or departments to contact for further information or explanation of duties under the plan

Training
Every employee needs to know the details of the emergency action plan including types of potential emergencies, evacuation procedures, alarm systems, reporting procedures, and shutdown procedures. Random emergency drills should be held at least annually. If possible, they should include outside police and fire authorities.

Emergency procedure training should be conducted when new employees are hired and at least annually thereafter. Additional training is needed when new equipment, materials or processes are introduced, when procedures have been updated or revised, and when exercises show that employee performance is inadequate.

Chain of Command
A chain of commend should be established so that employees know who has authority for making decisions. An emergency response coordinator and a backup coordinator should be designated. Adequate backup must be arranged so that trained personnel are always available. Coordinator duties include:

• Determining whether an emergency requiring activation of emergency procedures exists
• Directing all emergency activities including evacuation of personnel
• Ensuring that outside emergency services such as medical aid and local fire departments are called when necessary
• Directing the shutdown of company operations when necessary

Emergency Response Teams
The Emergency Response Teams are the first line of defense in emergencies. Team members should be thoroughly trained for potential emergencies and physically capable of carrying out their duties; know about toxic hazards in the workplace and be able to judge when to evacuate personnel or depend on outside help (e.g. when a fire is too large for them to handle). One or more teams should be trained in:

• Use of various types of fire extinguishers
• First aid, including cardiopulmonary resuscitation (CPR)
• Shutdown procedures
• Evacuation procedures
• Chemical spill control procedures
• Use of self-contained breathing apparatus (SCBA)
• Search and emergency rescue procedures

Communication
Effective emergency communication is vital. Employees must know how to report emergencies. And a method of communication should be established to alert employees to evacuate or to take other emergency action described in the plan. An alarm system should be in place, distinctive and recognizable enough to signal the emergency action.

An alternate area for a communications center may be necessary if the work site must be evacuated. The emergency coordinator should have an updated list of key personnel, of employees, and of employee relatives to be notified in case of emergency. There should be a system for accounting for personnel once they have been evacuated. The person in the control center is responsible for notifying police or emergency response team members of persons believed missing.

Personal Protection
Effective personal protection is essential for any person who may be exposed to potentially hazardous substances. In emergency situations employees may be exposed to a wide variety of hazardous circumstances, like chemical splashes, falling object, flying particles, unknown atmospheres with inadequate oxygen or toxic gases, fires, and live electrical wiring. It is extremely important the employees be adequately protected in these situation and that the equipment selected meet the criteria contained in Cal/OSHA standards. Some of the safety equipment that may be used includes:

• Safety glasses, goggles, or face shields for eye protection
• Hard hats and safety shoes
• Properly selected and fitted respirators
• Whole body coverings, gloves, hoods, and boots
• Body protection for abnormal environmental conditions such as extreme temperatures

Medical Assistance
In an emergency, time is a critical factor in minimizing injuries and damage. Employers not near an infirmary, clinic or hospital should have someone on site trained in first aid, have medical personnel readily available for advice and consultation, and develop written emergency medical procedures.

Employers should have first aid supplies for trained personnel to use, emergency phone numbers posted in conspicuous places near or on telephones, and prearranged ambulance services for emergencies. 

"Information or recommendations contained in these articles were obtained from sources believed to be reliable at the date of publication. Information is only advisory and does not presume to be exhaustive or inclusive of all workplace hazards or situations."