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Ergoweb - OSHA General Inspection Procedures

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Source: Bloswick, Donald S. Ergonomic Analysis of the Workplace Course Notes. Managed Health Resource Inc. and Industrial Ergonomics Inc., 1994, 12-14.

Triggering Criteria
OSHA has criteria for determining when an inspection is performed. The following is a prioritized list of situations in which OSHA conducts inspections adapted from the OSHA Compliance Manual.

  • Reports of alleged imminent danger situations.
  • Fatalities/Catastrophes (hospitalization of five or more employees).
  • Employee or union complaints (employee representative such as a doctor or lawyer).
  • Significant media events.
  • Referrals.
  • General scheduled-high hazard.
  • National, regional or local emphasis (such as safety and health in the chemical industry, pyrotechnics, or ergonomics).

Inspection Process
Typically, three things will happen during an OSHA inspection. The opening conference, the walkaround inspection, and the closing conference.

During the opening conference, the compliance officers(s) (CO) will present his/her credentials and discuss the purpose of the inspection. The records will be reviewed including the OSHA 200 log, mandatory written programs (such as hazard communication) and other documentation such as air sampling results. The existence of potential ergonomic hazards is determined through the overall rates of musculoskeletal injuries and illness and through concentrations of these illness/injuries in particular departments, work areas, jobs, or tasks as determined by analyzing the OSHA 200 log.

After analyzing the injury and illness logs, the Compliance Officer may conduct a "walkaround" inspection. During the walkaround inspection, special emphasis will be placed on those areas from which employee or union complaints have originated or which had concentrations of musculoskeletal incidents on the injury and illness logs. The CO may also perform environmental sampling (noise levels, presence of air contaminants, etc.). During the walkaround, the CO may also question employees about any job related symptoms they may have, what work areas they feel are problem areas, and about the training they have received.

Manual material handling problems (lifting and lowering injuries) are frequently analyzed through the use of the NIOSH Work Practices Guide for Manual Lifting. The NIOSH WPG provides information about the hazard involved in lifting/lowering a load as a function of the beginning and end points, the frequency, and the duration of the lift/lower. The upper extremity cumulative trauma disorder (UECTD) hazard is determined through an analysis of risk factors normally associated with these hazards. These factors generally include awkward postures, high movement frequencies and high hand or finger forces required to perform a task.

During the closing conference, the CO will explain any deficiencies that were noted and discuss any citations that may be issued. The ergonomic hazard indicated by the task analysis is considered along with the frequencies and types of injuries noted on the OSHA 200 Log or equivalent to determine if a citation is to be issued and, if so, the type of citation and magnitude of fine. The actual citation awarding and fine will be established by the Area or Regional Office. Citation amounts are assessed on the basis of the gravity of the situation, the size of the business, the good faith of the employer and the employer's history of previous violations.


 
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