As an employer, you can realize many benefits by conducting a self-audit of your workplace’s compliance with Occupational Health and Safety Administration (OSHA) regulations. An audit can help you pinpoint safety hazards and subsequently fix them to prevent employee illnesses and injuries. It can also help you avoid fines and citations by identifying and shoring up gaps in your compliance before OSHA discovers them.
Further, if your self-audit identifies a hazardous condition, and you promptly act to correct it and provide interim employee protection, but have not completely corrected the problem when an OSHA inspection occurs, the agency will treat the audit report as evidence of good faith, as opposed to a willful violation.
OSHA’s website has checklists, which vary based on company type, size and industry, to guide you through your self-audit. Below are some of the main points to include.
Companies with more than 10 employees in certain industries are required to keep records, using OSHA Forms 300, 301 and 301A, of all but minor work-related injuries and illnesses. Reportable injuries and illnesses must be documented within seven days of the company learning about them, and records must be retained for five years and produced within four hours upon request by OSHA. Form 301A, which is a summary of all reportable injuries and illnesses for the year, must be posted for all employees to see by February 1 of the following year and kept posted until April 30.
Companies must prominently display OSHA’s free poster informing employees of their health and safety rights. It should be hung in a place where employees gather, such as a kitchen or break room, along with emergency phone numbers, room capacities, signage for exiting the building, and appropriate information concerning any biohazards in the workplace.
Safety and health program
Employers should have an active safety and health program. This should include assigning someone to lead the program and creating a safety committee made up of management and labor or staff representatives that meet regularly. Employers should educate employees about their workplace health and safety rights and responsibilities while having a procedure in place for handling employee health and safety complaints.
Medical services and first aid
Workplaces that are not near a hospital, infirmary or clinic are required to have a trained first-aid provider on-site at all times. But even if your workplace is not required to do so, it is advisable to have dedicated individuals who are trained in first aid and made responsible for administering appropriate care. These individuals should be identified in your first aid response plan, and employees should be instructed to alert them promptly following an injury. First aid kits must be easily accessible to each work area, with supplies periodically inventoried and replenished as necessary. In areas where corrosive liquids or materials are handled, there must be easy access to a slop sink or another facility for flushing the eyes or body.
Protective measures in case of fire are vital to every workplace. Evacuation procedures must be implemented and communicated to employees, who should practice them with periodic fire drills. Portable fire extinguishers should be available in adequate numbers and easily accessible, with employees trained on how to use them. If there are fire alarm and sprinkler systems on premises, they must be inspected regularly, and fire doors must be in good operating condition. All exits should be unobstructed and clearly marked.
Personal protective equipment
Employers must provide appropriate personal protective equipment (PPE), which, depending on the industry and workplace type, can include protective clothing; protection for the eyes, face, head, and extremities; protective shields and barriers; and respiratory devices. Employers are responsible for assessing the workplace to determine if hazards are present or likely to be present that necessitate the use of PPE, and employees must be trained and required to use the appropriate PPE.
Depending on the workplace, your OSHA self-audit may cover additional areas, including stairways, elevated surfaces and walkways, lockout/tagout procedures, hand tools and equipment, among others. While there is no standard format for a self-audit, all audit reports should include the name of the person conducting the audit and the date that each category was checked. Any issues should be noted with a deadline to fix them, with interim safety precautions put in place where applicable.
By performing periodic self-audits of your OSHA compliance and fixing any problems that you uncover, you can help keep your employees safe while avoiding OSHA fines and citations.
Assistance with OSHA Compliance
Sheehy, Ware, Pappas & Grubbs can assist you with the complex OSHA compliance process and help you assert your rights throughout the OSHA inspection process. Few firms in the United States match our expertise in OSHA matters. Our OSHA attorneys have represented hundreds of clients in OSHA investigations, and we are able to perform 24/7 rapid response on-site coordination with our clients, often arriving before the OSHA inspector. For assistance with your OSHA matter, contact the OSHA attorneys at Sheehy, Ware, Pappas & Grubbs.