OSHA Program Audit

Posted March 15, 2017

OSHA PROGRAMS AND PROCEDURES

Are you in lost when it comes to OSHA compliance? Need assistance? Use this helpful guide as a resource when addressing all of your legal and contractual obligations, and to account for requirements that are specific to your industry, line of business, or project.

Hazard Communication – 29 CFR 1910.1200

1910.1200 (b) – Hazard Communication Program

Employers must inform employees of all hazardous chemicals that they may have contact with while performing their tasks in the workplace.

1910.1200 (e) (1) (i) – Chemicals Inventory List

Employers must keep an inventory of all hazardous chemicals that are used in the workplace. The chemicals inventory list should be reviewed regularly to see if any chemicals are missing.

1910.1200 (f) – Labels and Other Forms of Warnings

All hazardous chemical must be clearly labeled as such. Labels must include the name of the chemical, the name and address of the manufacturer and a notification of the appropriate hazards the chemical poses.

1910.1200 (g) – Material Safety Data Sheets (MSDS)

For each hazardous chemical in the workplace, the employer must provide an MSDS. These sheets must be readily available for any employee who would like to review them for more information about any hazardous chemical in their workspace.

1910.1200 (h) – Employee Information and Training

Employers must provide their employees adequate information and training regarding any hazardous chemicals in their work area. Training must inform the employee about safe interaction with the hazardous chemical(s) and also refer them to any written information the employer has been required to compile, like the MSDS.

Lockout/Tagout – 29 CFR 1910.147

1910.147 (a) (3) – Written Lockout/Tagout Program

Employers must establish and implement a procedure for the use of appropriate lockout or tagout devices to disable machines or equipment, keeping them from unexpected energization, start-up or release of stored energy.

1910.147 (c) (5) – Locks/Tags

All locks and tags used in a specific workplace must be durable (sufficient to withstand environment through its exposure to it), standardized (in at least color, shape or size), substantial (enough to require using excessive force or unusual techniques to remove it and to prevent accidental or inadvertent removal), identifiable (must indentify the employee who applied the device) and warn against hazards (for example: Do Not Start, Do Not Open, Do Not Close, Do Not Energize or Do Not Operate).

1910.147 (c) (6) – Periodic Inspections

Conduct periodic inspections of all employees who use lockout/tagout devices to make sure that proper procedures are being followed and shutdown procedures are adequate.

1910.147 (c) (7) – Training and Communication

Employers must provide training that instructs employees on the purpose and function of the energy control program with special focus on the safe application, use and removal of devices.

Hearing Conservation – 29 CFR 1910.95

1910.95 (b) (1) – Permissible Noise Levels

When employees are subjected to sound exceeding the levels laid out in the following chart, employers must reduce noise levels through administrative or engineering controls. If this does not adequately reduce exposure, employers must provide protective equipment for employees.

Duration of exposure per day in hours	Sound level in dBA slow response
8	90
6	92
4	95
3	97
2	100
1 ½	102
1	105
½	110
¼ or less	115

1910.95 (k) – Employee Training Program

Employees need to be informed about the risks of constant noise exposure and how to reduce its effects. At this time, it is also necessary to train employees about the advantages and disadvantages of certain types of hearing protection along with how to properly fit, use and care for such devices.

Respirator Protection – 29 CFR 1910.134

1910.134 (c) – Written Respirator Program

If respirators are necessary to protect the health of employees, employers must establish and implement a written respirator program that outlines worksite-specific procedures.

1910.134 (e) – Medical Questionnaire/Evaluation

All employees required to wear respirators must fill out a medical questionnaire or undergo a medical examination to determine the employee’s ability to work with a respirator.

1910.134 (f) – Fit-Testing

All employees required to wear respirators must complete a fit-test prior to initial use. Employees must be fit tested with the same make, model, style and size of respirator they will be using. Follow-up tests are required on an annual basis to ensure that respirators are providing the maximum amount of protection.

1910.134 (k) – Training and Information

Employers must provide effective training to affected employees on:

Why the respirator is necessary and how improper fit, usage or maintenance can compromise the protective effect of the respirator;
Respirator limitations and capabilities;
How to use the respirator effectively in emergency situations;
What to do if the respirator malfunctions;
How to inspect, put on and remove, use and check respirator seals;
The procedures they must follow for respirator maintenance and storage; and
How to recognize the medical signs and symptoms that may limit or prevent effective use of respirators.

Personal Protective Equipment – 29 CFR 1910.132

1910.132 (d) – Hazard Assessments

Employers are expected to make a written assessment of the workplace to determine if hazards are present, or likely to be present, that require the use of personal protective equipment (PPE). If any hazards are found, the employer must select applicable forms of PPE and require employee use.

1910.132 (f) – Employee Training

Employees must receive training that covers:

When and what PPE is necessary;
How to properly don, doff, adjust, wear and use the necessary PPE;
PPE limitations; and
Proper care, maintenance, useful life and disposal of PPE.

Confined Spaces – 29 CFR 1910.146

1910.146 (c) (1) – Identifying Confined Spaces

Employers need to evaluate the workplace to determine if any spaces are permit-required confined spaces. A confined space has one or more of the following characteristics:

Contains, or has the potential to contain, a hazardous atmosphere;
Contains a material that has the potential to engulf an entrant;
Has an internal configuration that could trap or asphyxiate an entrant (inwardly-converging walls or sloping floor tapering to a smaller cross-section); or
Contains any other recognized safety or health hazard, such as unguarded machinery, exposed live wires or heat stress.

1910.146(c) (2) – Warning Signs

If a workplace has areas determined to be permit-required confined space, the employer must mark all entrances with signage to warn employees of its existence, location and possible dangers.

1910.146 (c) (4) – Entry to Confined Space

In the event that employees need to enter any area labeled as a confined space, they must obtain a permit from their employer. The permit system serves as a checklist to make sure the space is as safe as possible before entry and while any work is being done inside. During the time an employee is working in the space, they must be monitored from the outside by another employee.

Emergency Response – 29 CFR 1910.38

1910.38 (a) – Employee Emergency Plans

This plan should addresses emergencies that an employer can reasonably expect in the workplace and list the steps employees must take in their event. Emergency examples include fires, hurricanes, tornadoes, toxic chemical spills and floods.

1910.38 (c) Minimum Requirements of an Emergency Plan

At minimum, an emergency plan must include the name and job title of individuals employees can contact if they want more information on the emergency plan or an explanation of their duties under the plan and procedures for:

Reporting a fire or other emergency;
Emergency evacuation (including evacuation and exit route assignments);
Employees who must remain behind to operate critical plan equipment before they evacuate;
Accounting for all employees who are required to evacuate; and
Employees who perform rescue or medical duties.

1910.38 (e) – Emergency Action Plan Training

Employers should train a number of employees as wardens to assist in providing guidance and instruction during emergencies. Wardens can make sure employees evacuate in a safe and orderly manner and that specific areas are clear and secure after all employees have exited. Consider assigning one warden for every 20 employees.

Bloodborne Pathogens – 29 CFR 1910.1030

1910.1030 (c) – Written Exposure Control Plan

Employees must be provided with written documentation of what tasks and procedures carry a risk of occupational exposure. The control plan will be used to identify the employees that need further training for dealing with bloodborne pathogens.

1910.1030 (g) (2) – Information and Training

Employers must provide all employees who have a chance for occupational exposure with the appropriate safety training, at no cost to the employee and during work hours. The first training needs to be completed at the time of, or before, the employee’s first assigned task that has a chance for exposure. Training must be conducted annually thereafter.

Forklifts – 29 CFR 1910.178

1910.178 (l) (2) – Training Program Implementation

In order for employees to operate a powered industrial truck, they must undergo training that consists of a combination of formal classroom instruction, practical, hands-on training under instructor supervision and a review of the operator’s performance in the workplace.

1910.178 (l) (4) – Refresher Training and Evaluation

Operators will need to undergo a refresher safety course and evaluation if

The operator is required to operate a new type of truck;
The operator has been observed to operate the vehicle in an unsafe manner;
The operator has been involved in an accident or near-miss incident;
The operator’s evaluation reveals he or she is not operating the vehicle safely; or
A condition in the workplace has changed in a way that could affect the safe operation of the truck.

1910.178 (q) (7) – Inspections

To ensure employee safety, industrial trucks need to be examined before being placed in service. Such examinations shall be made at least daily. If an industrial truck is used on a round-the-clock basis, it should be examined after each shift. When found, defects must be immediately reported and corrected.

It must not be assumed that every unsafe condition or procedure has been covered in our survey. Further, we make no representation nor assume any responsibility that locations, products, work places, operations, machinery and equipment are safe, or healthful, or in compliance with any law, rule, or regulation.