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By Charles Carpenter
Published in the February 2011 issue of Today’s Facility Manager
When most facility professionals hear they have a call from OSHA (or even worse, a visit is pending), I imagine that OSHA is not first thing that comes out of their mouths. While very few people look forward to an OSHA inspection, at the end of the day, these inquiries or visits are valuable to the facility manager (fm).
The truth is that anyone can contact OSHA about anything work related. Someone unsafely using an aerial lift? That’s a good call. Someone complaining about the cleanliness of the restroom and the quality of the toilet paper? Now that’s a bit trivial.
OSHA takes all reports seriously. It may just not prioritize the ones from workers who prefer Angel Soft over Cottonelle. For minor complaints, OSHA will probably ask the fm for a complete report, document any collaborating evidence, and post a response where all employees can access it. OSHA will then contact the anonymous complainer to relay any conclusions that have been reached. For many cases, this is the end of the road.
For more serious infractions, an fm can expect an on-site visit from an OSHA inspector and the opportunity to correct the problem. The most egregious offenders may find themselves slapped with a large fine, such as OSHA’s proposed $558,000 penalty in response to the U.S. Postal Service for electrical hazards at a Providence, RI facility. (There’s also a record breaking $87,430,000 fine against BP Products North America Inc. for the company’s failure to correct potential hazards faced by employees. This violation dates back to October 2009.) For the truly dangerous infractions, a facility could be closed until the problem is addressed.
Despite misperceptions, OSHA should be seen as the fm’s friend. This organization offers free consultation for smaller companies, a multitude of information for fms, and numerous programs designed to make facilities safer. In short, OSHA wants to work with you, not against you.
Joann Natarajan of the Austin, TX area office of OSHA recently offered up some of the common, easily avoidable infractions found in facilities (including poor hazard communication), which can encompass anything from a complete lack of a hazard communication program to the simple absence of a Material Safety Data Sheet (MSDS). Natarajan offered the following, easily achievable suggestions for fms:
- Lack of a written hazard communication program;
- Inaccurate lists of hazardous chemicals at a facility;
- Missing MSDS (including in company vehicles), or the absence of an MSDS in a language an employee can read or have translated;
- Unlabeled containers of chemicals, from the large containers chemicals may arrive in, to the small bottles a janitor may use for a diluted mixture;
- Unlabeled equipment that contains chemicals;
- Inadequate personal protective equipment (PPE) for each job;
- No training or documentation on using PPE;
- Failure to follow the rules for permit required confined spaces, such as air handlers or tanks;
- Lack of exposure control for bloodborne pathogens;
- Improper disposal of regulated waste;
- No annual training for working with hazardous material; and
- Deficiency in the use of NIOSH approved respirators.
So here are a few OSHA-related issues for those who may want to know. Feminine napkin receptacles, which may contain bloodborne pathogens, are not considered regulated waste; however, janitorial crews should be adequately trained in handling these waste products. Chemicals and cleaners purchased from a retailer do not require additional labeling if the manufacturer provides detailed information about the product and the product is kept in its original container. Labels can be produced by the industrious fm; meaning that an fm can make his or her own labels in large quantities for specific products or as blank labels.
It is easy for the even most prudent fm to have an infraction. A contractor might start using a new chemical without updating the hazard label or hire a new employee without proper training. A new MSDS may come out for a cleaner that recently underwent a formula revision. An employee can decide to ignore a written rule “just this once” because of expediency. The trick is to be proactive with a safety program that includes common sense and looks for common violations. The alternative may leave fms saying “oh sh–” the next time they hear from OSHA.