As seen in Hammer & Dolly September 2015
In previous articles, we have discussed being proactive with regard to OSHA regulations in the shop. The basics, included hazard communication, a.k.a. “Right to Know”, personal protective equipment (PPE), and respiratory protection. Though there are many other regulations, these are some of the most commonly cited laws in the automotive industry.
OSHA’s Isocyanates Enforcement Program or IEP has been a national priority since June of 2013. The goal has been to reduce or eliminate the adverse health effects of occupational exposure to isocyanates used in catalyzed products like bedliner and activated paints. This IEP has put body and paint shops squarely in the sites of OSHA, increasing inspections.
We have received more than a few emails and phone calls regarding this increased level of shop inspections. Some questions included; “Do I have to let them in my shop?”, and “What can I do if the inspector shows up?”
Firstly, OSHA has a legal right to inspect workplaces. Businesses have a legal right to require a warrant. While that may be true, one must realize that beginning a relationship on an adversarial note is generally not a good idea. The vast majority of inspectors are dedicated safety professionals and not there to “bust” you. Most also realize that if you are legitimately too busy to give your full attention to the inspector, she will make every reasonable effort to accommodate you.
Now, what to do if an inspector is at your door. If they aren’t there yet, you have time to prepare!
The first step is to evaluate where you are versus each standard. Look at your safety programs and training records, are they current? Look around your shop for violations. Some will be obvious, such as trip hazards and employees not wearing PPE, others a more technical in nature. Ask your employees what they see as dangers in the workplace. Most business owners and employees genuinely care about their work family. If you demonstrate this, the culture will be evident when the inspector speaks with your people.
If the inspector is there, some basics that should make things go easier include the following. Be respectful. Give the inspector your undivided attention, or at the very least assign a senior manager.
Be honest. Lying to an inspector is a federal crime.
Have your safety programs handy. This will convey the sense that you take what they do for a living seriously.
It is crucial that you accompany the inspector. Take notes and feel free to ask for clarification on items you do not fully understand. Eliminate any hazards as soon as you have been made aware of them. For example, if there is a frayed power cord, cut it to make the equipment unusable. Be sure to unplug it first!
Don’t be defensive. Thank the inspector for pointing out a potential violation and explain how you will correct it. During the walkthrough, explain your efforts to make your shop safe and compliant.
A regulatory inspection can be a stressful event. When it happens, take a deep breath. Hopefully, knowing what the process is will make it easier to prepare for and to get through.
Next time we will discuss what happens after the onsite inspection. I hope this information is helpful. If you have any questions, give me a call.