Have you ever feared the reality of OSHA showing up at your Ohio food business for an OSHA inspection?
You’re not the only one.
In fact, in 2017 OSHA conducted 32,396 federal inspections, and 43,551 state plan inspections.
Because OSHA is responsible for the health and safety of over 130 million workers that are employed at more than 8 million worksites across the country.
Let’s just say…they have a major task at hand – “…to assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance.”
And regardless of how safe and healthy your workplace environment is, your Ohio food business should be prepared in the event that OSHA shows up knocking.
Who can be inspected by OSHA and why?
OSHA regulations indicate that OSHA inspections can happen at any factory, plant, manufacturing facility, establishment or other workplace to investigate all pertinent conditions, structures, machines, equipment and materials without notice.
OSHA inspectors (also referred to as compliance officers) prioritize inspections in the following order:
- Imminent danger situations: Top priority is given to hazards that could cause death or serious physical harm. Employers must immediately correct or remove employees from the facility.
- Fatalities or catastrophes: Incidents where three or more employees die or are hospitalized. Employers are required to report such incidents within eight hours.
- Complaints: Allegations of hazards or violations by employees.
- Referrals: Reports of hazard information from federal, state, or local agencies, individuals, organizations or the media.
- Follow-ups: Verification by compliance officers that previously cited violations are corrected.
- Planned or programmed investigations: Inspections of high-hazard industries or workplaces with high rates of injuries and/or illnesses.
- Random Audits: Even employers with clean safety records may be subject to OSHA inspection.
What can your Ohio food business do to help prevent and also prepare for a surprise OSHA inspection?
Here’s a good place to start…
Identify the most frequently cited standards for food manufacturers, and then find and fix recognized hazards in your Ohio food business that are addressed in these and other standards before OSHA shows up at your doorstep.
Here’s OSHA’s top three most frequently cited standards for food manufacturing in 2017:
- Control of Hazardous Energy (Lockout/Tagout)
- General Requirements for All Machines
- Process Safety Management of Highly Hazardous Chemicals
Let’s go a little more depth on each of these standards:
Control of Hazardous Energy (Lockout/Tagout)
“Lockout/tagout (LOTO) refers to specific practices and procedures to safeguard employees from the unexpected energization or startup of machinery and equipment, or the release of hazardous energy during service or maintenance activities.” (osha.gov)
If your employees service or maintain machines where the unexpected startup, energization, or the release of stored energy could cause injury, the standard likely applies to you.
- Average cost per violation: $6,291
Click here for a Lockout/Tagout Self-Inspection Checklist which covers the servicing and maintenance of machines and equipment in which the unexpected energization or startup of machines or equipment, or release of stored energy could cause injury.
General Requirements for All Machines
OSHA specifically states that the point of operation of machines whose operation exposes an employee to injury, shall be guarded.
There are two types of machine guards: fixed and interlocking.
Fixed guards are most commonly used and are generally preferred because they protect you from dangerous parts of machines at all times.
Interlocking guards are only used if a fixed guard is not practical. This type will allow the machine to operate until dangerous parts are guarded. The interlocking guard is designed to disconnect the source of power from the machine.
- Average Cost Per Violation: $8,793
Process Safety Management of Highly Hazardous Chemicals
To help ensure safe and healthful workplaces, OSHA issued this standard to prevent and minimize the consequences of catastrophic releases of toxic, reactive, flammable or explosive chemicals that may result in toxic, fire or explosion hazards.
Process Safety Management (PSM) emphasizes the management of risks associated with highly hazardous chemicals and establishes a comprehensive risk management program that integrates technologies, procedures and management practices.
- Average Cost Per Violation: $6,475
Here’s the bottom line.
No business is immune to a visit from OSHA. Even the largest businesses with the best risk management and safety programs are still subject to an OSHA inspection.
So who’s to say that your Ohio food business isn’t next?
Invest some time into reviewing your risk management and safety programs to ensure you have the right policies and procedures in place to maintain a healthy and safe workplace that is compliant with OSHA law.
As a food and agribusiness recall protection specialist at The O’Neill Group, I have access to a myriad of resources that can help you with OSHA compliance. From timely updates on new and revised OSHA rules and regulations, to digital recordkeeping platforms, inspection checklists and employee safety trainings, just to name a few.
If you would like to learn more about our free OSHA compliance tools and resources, please email me at firstname.lastname@example.org or call me at (330) 334-1561.
This article was adapted from Zywave. This is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel or an insurance professional for appropriate advice.