“Hello. I’m from OSHA and I am here to help you.”
If you own or operate a private club, chances are very good you’ve heard these dreaded words before. Next to, “Hello. I’m from the Internal Revenue Service,” there are few greetings more inclined to make your knees weak. But it doesn’t have to be that bad.
Almost all OSHA inspections begin with a review of your injury and illness records, safety manual, OSHA-required programs, OSHA-implied programs, safety procedures, and training records. Here are some additional areas you should concentrate on to make things go smoothly:
Make sure you have a proper Safety/IIPP Program in place. Most successful injury and illness prevention programs are based on a common set of key elements. These include: management leadership, worker participation, hazard identification, hazard prevention and control, education and training, and program evaluation and improvement. Does your club meet these criteria?
Electrical Power Panels. Missing covers and free access to exposed energized electrical parts are very common safety hazards in works involving electricity. Replacing missing covers in electrical panels and boxes, and covering the openings that have unrestricted access to exposed energized electrical parts save workers from the danger of shock and electrocution. And don’t have someone who is color-blind do the wiring, OSHA looks for grounded conductors to be white or grey and equipment grounding conductors be differentiated from other conductors via green wire or green with yellow strips.
Tools & Equipment. Make sure none of the cords are frayed and interior wiring is not exposed. Also, make sure the plastic piece where the prongs are is not damaged.
Fire Extinguishers. There are three major points of interest here, particularly to an OSHA inspector. Visibility is key. Is it clearly marked by signage, even in a relatively smoky room, exactly where fire extinguishers are located? Are the extinguishers in close proximity to where they may possibly be needed in an emergency? Have they been recently inspected and noted by an inspector with initials and date?
Labeling of containers. You should never have to guess what’s in a bottle or plastic container. Make sure every container is labeled clearly and precisely as to its content. It’s also not a bad idea to date each label (for expiration purposes) and have the person filling out the information initial it.
Storage and handling of cylinders. Gas cylinders should be properly secured at all times to prevent tipping, falling or rolling with straps or chains connected to fixed surface. The cylinders should be stored in a cool, dry, well-ventilated, fire-resistant area, and when empty make sure the valve is closed, the regulator removed and that the valve protector cap is secured in place.
When the inspection is completed, the CO will review any apparent violations and discuss possible methods for correcting the violations within a reasonable time period. The citations will include:
>> A description of the violation
>> The proposed penalty if any
>> The date by which the hazard must be corrected
Employers have 15 working days upon receipt to file an intention to contest OSHA citations. Common causes to dispute citations include:
>> The citation is false
>> The citation’s dollar penalty is excessive
>> You disagree with the citation’s contention that the danger was real, serious, and that an accident was likely to occur
There is no way to avoid an OSHA audit, much like there is no way you won’t eventually hit your thumb with a hammer when hanging a picture. But you can lessen the pain by being well-prepared.
