OSHA UPDATE PANELMonday, October 3, 2011

Kevin Kilp, Area Director, HarrisburgJean Kulp, Area Director, Allentown

Mark Stelmack, Area Director, Wilkes-Barre

Rev:30 Sept 2011

• Inspection Targeting• Regulatory Agenda• Updates• Website Tools• Where Do I go for help• Questions and Answers

Overall Agenda:

REGION III

Regional Administrator:

Deputy Regional Administrator: Kurt Petermeyer

Pennsylvania OSHA Area Directors

Rev: 14 Aug 2008

Jean Kulp

Theresa Naim

Kevin Kilp Albert D'Imperio

Mark Stelmack

Robert Szymanski

How Does OSHA Decide Who to Inspect?

OSHA cannot inspect all workplaces it covers each year. The agency seeks to focus its inspection resources on the most hazardous workplaces.

DIRECTIVE NUMBER: CPL 02-00-148

http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-00-148.pdf

OSHA INSPECTIONS Inspection/Investigation Types

Inspection Priorities:

• Unprogrammed inspections:

– Imminent Danger

– Catastrophes and Fatal Accidents

– Complaints and Referrals

– Follow-up Inspections

OSHA INSPECTIONS Inspection/Investigation Types

Inspection Priorities:• Programmed Inspections:

– Site-Specific Targeting (SST),– Construction– Scheduling for Maritime Inspections – Special Emphasis Programs (SEPs). – National Emphasis Programs (NEP), – Regional (REP) & Local Emphasis Programs

(LEP),– Other Special Programs.

Site-Specific Targeting 2011 (SST-11)

DIRECTIVE NUMBER: 11-03 (CPL 02)

EFFECTIVE DATE: September 9, 2011

Sept 2011

http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-11-03.pdf

http://www.osha.gov/pls/oshaweb/owadisp.show_document?

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OSHA INSPECTIONS(SST-11)

• Site Specific Targeting (SST) • Comprehensive• 3 Categories:

– Manufacturing Establishments– Non-Manufacturing Establishments– Nursing and Personal Care Facilities

• Based upon DART and DAFWII Rates

  Primary Secondary Tertiary

Manufacturing Establishments:    

DART 7.0 5.0 OSA

DAFWII 5.0 4.0 Discretion

Non-manufacturing Establishments:    

DART 15.0 5.0 OSA

DAFWII 14.0 4.0 Discretion

Nursing and Personal Care Facilities (805)    

DART 16.0 13.0 OSA

DAFWII 13.0 11.0 Discretion

OSHA INSPECTIONSSite Specific Targeting (SST-11)

Injury and Illness Recordkeeping

National Emphasis Program

(RK NEP)

DIRECTIVE NUMBER:

10-07 (CPL 02)

EFFECTIVE DATE:

September 28, 2010

EXPIRES:

February 19, 2012http://www.osha.gov/OshDoc/Directive_pdf/CPL_02_10-07.pdf

https://www.osha.gov/pls/oshaweb/owadisp.show_document?

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Appendix A

Verification of each Recordable Injury and Illness Record

Onsite inspection to review CY 2008 and CY 2009 injury and illness records:

• Medical records• Worker’s compensation records• Insurance records • Payroll absentee records• Company safety incident reports• Company first-aid logs• Alternate duty rosters• Disciplinary records pertaining to injuries and illnesses.Note: This includes records stored on and off site.

Example Recordkeeping Citations

Failure to :• record injuries or illnesses on the OSHA 300 form.• record a case correctly• adequately describe the location • provide a specific description• enter the correct number of calendar days • not completing or not accurately completing the OSHA 301• complete an OSHA 300A.• provide copies of records • …

http://www.claimsjournal.com/news/midwest/2010/05/03/109492.htm

Company fined $182,000 for failing to record worker injuries and illnesses

OSHA issued eight citations to Company Inc. and fined the company $182,000 for failing to document and report worker injuries and illnesses at its distribution center. OSHA inspectors found that Company had willfully disregarded its responsibilities to comply with OSHA regulations by continuously failing to correctly classify worker injuries or illnesses and not correctly recording the number of days a worker was away from work due to injury or illness. Additional recordkeeping violations found by inspectors included two for which the company had been cited previously. See the for more information on the failure of Company to report worker injuries.

Apart from this particular investigation, OSHA has implemented a NEP to assess the accuracy of information on workplace injuries and illnesses recorded by employers.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?

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OSHA INSPECTIONS

National Emphasis Programs (NEP) Sept 2011

• Combustible Dust• Federal Agencies (includes FAA)• Flavoring Chemicals (Diacetyl)• Amputations (Hazardous Machinery)• Hexavalent Chromium• Lead • Primary Metals• PSM Covered Chemical Facilities • Petroleum Refinery Process Safety Management• Injury and Illness Recordkeeping• Shipbreaking• Crystalline Silica (follow-ups)• Trenching and Excavation

http://www.osha.gov/dsg/combustibledust/index.html

National Emphasis Program (NEP) on

Hexavalent Chromium

http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-02-076.pdf

OSHA Directive CPL 02-02-076, Feb. 23, 2010

OSHA compliance assistance resources:

What is Hexavalent Chromium?

• Toxic form of chromium metal that is generally man-made

• Used in many industrial applicationsprimarily for its anti-corrosive properties

• Can be created during certain “hot” work processes where the original form of chromium was not hexavalent

Sept 2011

Sept 2011