Unit II Assignment

BOS 3525, Legal Aspects of Safety

Santiago Rodriguez

Columbia Southern University

Abstract

I receive a follow-up call from the area director saying the employee filing the original non-formal complaint has provided additional information about the alleged health situation and submitted a formal complaint using the OSHA-7 form, making the complaint a formal complaint. A few days later, an OSHA compliance officer shows up at my facility to perform a comprehensive inspection. The compliance officer presents the proper credentials, and I’ve verified that the compliance officer is employed by OSHA and assigned to the local office. During the opening conference, the compliance officer provides me with the formal complaint, alleging the compliance officer asks for a private conference room and a list of non-managerial employees. He tells me that he intends to interview four non-managerial employees before leaving for the day. He also states that he will return the next day to collect some air samples at the facility. The compliance officer asks for a private conference room and a list of non-managerial employees. He tells you that he intends to interview four non-managerial employees before leaving for the day. He also states that he will return the next day to collect some air samples at the facility. I am quite worried about the number of citations and penalties that we as a company may face. Provided are documents summarizing the steps I would take as soon as the compliance officer leaves and the steps I believe I could have taken during the walk-through. Provided are documents with summarizations and the steps I will take as soon as the compliance officer leaves and the steps I believe I could have taken during the walk-through that may have resulted in a quick-fix penalty reduction.

BOS 3525, Legal Aspects of Safety

OSHA’s mission is to assure the safety and health of America’s working men and women by promulgating and enforcing standards and regulations; providing training, outreach, and education; establishing partnerships; and encouraging continual improvement in workplace

safety and health as well as the development of comprehensive safety and health management systems. Occupational Safety and Health Administration. (2016). Field Operations Manual. Retrieved from https://online.columbiasouthern.edu/CSU_Content/courses/Emergency_Services/BOS/BOS3525/15F/FOM2016.pdf

This a detailed step by step guide to what corrective measures will be taken in order to comply with said OSHA standards and regulations, and by taking immediate corrective measures and thus to insure the safety of all our employees at the company. This will help better establish a better rapport with the agency, and help us in the long run of becoming an even safer company.

The first issue that must be addressed is the haze that is present in the welding shop. The following steps will be implemented to correct this issue:

Hire a third party consultant for the purpose of testing and re-testing the air quality in the shop.

Test all ventilation equipment to verify that all the equipment is in perfect working condition.

The second issue underlined was the employees wearing half-mask air purifying respirators with full beards. This issue could have had a quick fix response by having the employees shave off the beards before fit testing could be re-issued. The following steps will be implemented to correct the issue:

All employees who must wear a half-mask respirator must be clean shaven whenever preforming job specific duties that require air purification.

All employees shall be identified by job foremen and supervisors stating they require special air purifying equipment to preform there job duties.

All employees must remain clean shaven during employment of this company or be subject to disciplinary action the company to which they are employed.

The third issue where employees are using chemicals with no eye wash station is present, eye wash station that is available is dusty and no presence of recent use is available. Employees are using chemicals that may be absorbed by the skin, and are not using gloves. The following steps will be implemented to correct this issue:

Site Safety technicians will perform and update safety inspection logs on all eye wash stations in the facility.

Each area where chemicals are being used in close proximity will have access to clean eye wash stations.

Retrain all employees in chemical safety and proper PPE procedures and requirements underlined in the SDS (Safety Data Sheets).

All employees not wearing the proper PPE will be subject to disciplinary action by the employer.

The fourth issue is the employees are preforming maintenance inside a press without locking out the equipment and also no written LOTO procedure at the time of inspection. The following steps will be implemented to correct this issue:

Develop and implement a LOTO procedure and policy.

Train all authorized and affected employees in the newly implemented LOTO procedures.

Management, Supervisors, and leads will have daily tail gate meetings with all employees to better communicate and give a better understanding of current procedures.

All equipment requiring LOTO procedures will have written procedures in order to better understand de-energizing procedures.

The Fifth issue is welding operation is performed near flammable materials, and no fire watch is present. This could have been another quick fix solution by having the welder’s helper stand in as the fire watch. The following steps will be implemented to correct this issue:

All welding jobs will be performed no less than 35 ft. away from flammable material, and will be subject to special job specific permits approval by a supervisor, also a trained fire watch person must remain in the presence of the work being conducted.

All employees that preform welding jobs will be re-trained on all requirements associated

with safety.

The sixth issue is there is no record of training for fork truck drivers. The following steps will be implemented to correct this issue:

Contact a third party forklift truck training company and certify all employees operating said trucks.

Document and store all certifications where they will be readily available upon request.

Implement a written policy stating rules and regulations associated with operating a forklift truck, and issue disciplinary action to all employees not complying with guidelines.

The seventh issue is extension cords are stretched across walkways. This issue was perhaps the easiest of all the quick fix solutions, by either placing cord guards over them or simply removing them from exposed walk ways.

The eighth issue was three containers are present in the plant with no label present on any of the container. The following steps will be implemented to correct this issue:

Contact an Industrial Hygienist in order to perform an analysis on containers to determine what chemicals are present in the container.

Preform a survey on all containers on the job site in order to determine what chemicals are present. If any labels are fading, peeling, or missing contact chemical company in order to receive new labels.

The final issue was an employee could not find a SDS for the chemical he or she was using.

The following steps will be implemented to correct this issue:

Preform a study on all chemicals being used or available on company premises in order to insure they all have an SDS sheet.

Keep an online data base of all chemicals and SDS stations used by the company for easy access for any employee that may need it.

Train all employees on how to access the online data base.

Make sure that all newly purchased chemicals entering the job site come with an SDS sheet.

This is a detailed guideline of what we will do as a company in order to insure all of our employees have a safe and clean worksite. I look forward to meeting with you once again in order to discuss the progress of our company. Thank You.

Reference

Occupational Safety and Health Administration. (2016). Field Operations Manual. Retrieved fromhttps://online.columbiasouthern.edu/CSU_Content/courses/Emergency_Services/BOS/BOS3525/15F/FOM2016.pdf