Preparing to survive an OSHA inspection: paying attention to what inspectors are looking for could lead to an OSHA visit without citations - and a much safer foundry.

Paying attention to what inspectors are looking for could lead to an OSHA visit without citations - and a much safer foundry.

If one of your employees runs in and tells you an Occupational Safety and Health Administration (OSHA) compliance officer has just arrived to inspect your facility, it will be too late to identify or correct unsafe conditions in the foundry.

But whether or not you've been working to implement practices that comply with OSHA regulations, you need to know which conditions the OSHA representative will be inspecting.

After the Compliance, Safety and Health Officer (CSHO) identifies himself or herself with the proper credentials and states the purpose of the visit, the officer generally begins the inspection by asking about your safety and health programs.

Before conducting a walk-through inspection, the CSHO will ask to review written programs and records. Any standard that requires training needs to have written documentation. This documentation is the most effective proof that training has taken place. If the foundly has written plant safety rules and procedures, volunteer to show them to the CSHO - He or she will probably ask for them.

Documents and Records

The CSHO will want to review many documents and records. Figure 1 shows the most frequently cited standards in 1991. Here are a few of the major standards to be concerned with:

Written Hazard Communication Program (1910.1200): The program should include information on the hazardous materials list, MSDS filing, labeling, informing contractors and training. The written program should be specific to the foundry and contain only information relevant to the facility.

The CSHO will also thoroughly review employee training, which was the number one general industry standard cited in 1991.

Lockout/Tagout (1910.147): The written program must describe the prevention of employee injury as a result of the unexpected energization or start-up of machines and equipment or the release of stored energy. Foundry employee and contractor training is required.

OSHA Records, 200 LOGS (1904.2): The current calendar year log should be up to date and logs for the past five years must be available. Personal accident records - both current and over the last five years - also need to be available. The information contained in these records plays an important role in determining how a CSHO will use his/her time during the foundry's inspection. If the records reveal patterns or concentrations of particular types of injuries, the CSHO will concentrate on those areas.

Employee Emergency Plans/Fire Prevention (1910.38): Foundries with 10 or more employees must have a written emergency action plan covering such issues as: emergency escape procedures and routes; procedures for those remaining to operate critical equipment, if applicable; accounting for all employees after evacuation has been completed; rescue and medical duties; methods of reporting emergencies and fires; and names and job titles of people who can be contacted for further information.

In addition, the foundry must establish an employee alarm system.

Foundries with fewer than 10 employees don't need a written program and can communicate escape plans verbally. Training, however, is required.

Hazardous Waste Operations and Emergency Response (HAZWOPER) (1910.120): If workers respond to emergencies such as spills or leaks at the foundry, a written program along with employee training is required. The standard applies when foundly employees respond to an uncontrolled release. The standard doesn't apply if employees respond to incidental releases where substances can be controlled by workers and the response poses no more of a risk than what is normally present.

Bloodborne Pathogens Standard (1910.1030): This is a new standard for preventing the transmission of bloodborne pathogens (HIV, hepatitis, etc.) by limiting occupational exposure to blood and other infectious materials. OSHA applies the standard to any employee who has been identified formally or informally by the company to administer first aid.

The Walk-Through

After the CSHO reviews documents and records, a physical inspection of the plant takes place. Depending upon the information found in the 200 logs, the CSHO concentrates on areas where the most injuries or illnesses have occurred. The more important general areas of concern for foundries are HAZWOPER, lockout/tagout and hazard communication.

HAZWOPER

Before the walk-through inspection, the CSHO most likely will inquire about the foundry's response to emergency releases.

Remember: the foundry must have an emergency evacuation plan. If the foundry doesn't have such a plan, the CSHO probably will check the response equipment during the walk-through. If the foundry manager indicates to the CSHO that foundry employees respond only to incidental releases, the CSHO may interview workers to determine the types or releases to which they have responded in the past.

A citation is possible if the CSHO believes that employees don't respond to an emergency as defined by the standard and if the foundry has no formal HAZWOPER program.

If the foundry has no intent to implement an emergency response procedure, the manager should indicate in writing that the foundly responds only to incidental releases. Company officials should also document if emergencies are handled by outside response organizations, such as HAZMAT teams, fire departments and cleanup firms.

Lockout/Tagout

Aside from reviewing the written plan, the CSHO may investigate: * Whether the locked and tagged energy

isolation device is marked to

describe the equipment it controls. * whether the lockout/tagout devices

are marked to indicate which employees

may apply the lock. * whether the locks are specific to the

task of lockout only and are not multipurpose 

locks. * whether only authorized employees

are performing the lockout/tagout.

The entire standard should be read for additional requirements.

Hazard Communication

Manufacturers received more citations for noncompliance with this standard than with any other.

The CSHO reviews the written program, MSDS files and training documents before the walk-through inspection, during which he considers: * whether a current chemical inventory

list is posted. This is a list of all the

hazardous materials processed in the

foundry. * whether all containers in the foundry

have the appropriate hazard warning

labels. * whether containers with hazardous

materials, other than transfer containers,

have warning labels. * whether the MSDS file contains a current

MSDS for every hazardous material

in the foundry. * whether MSDSs are available for all

the workers during all shifts.

Post-Inspection Rewards

Making the effort to comply with OSHA regulations brings two rewards. First, when the inspector finds reasonable conditions and documentation, you know you're providing your employees with a safe and conscientious work environment. Second, you're avoiding steep fines - up to $70,000 - in an economic situation where that money can be put to much better use in your foundry.

Foundry employees are urged to further investigate OSHA standards that may affect their facility and to be constantly aware of potentially unhealthy, unsafe or hazardous conditions in the workplace.

Foundries can obtain assistance from various sources to help them provide a safe and healthy workplace to comply with OSHA standards. These resources include workers' compensation carriers, trade associations, suppliers, distributors and fire insurance carriers.

The more a foundry knows about the condition of its workplace, the easier it will be to comply with the applicable standards and to provide its employees with a good place to work.

Do's and Dont's of an Inspection

An OSHA inspector for 12 years, Jim Barry, Wisconsin Dept. of Occupational Health, Madison, Wisconsin, offers this advice to foundry officials for handling OSHA inspections:

* Don't panic. Remain rational.

* Make sure he/she is a real CSHO.

* Ask how you were picked and what is the scope of the inspection.

* Only ask for a warrant if you have a valid reason.

* Treat the inspector as you would like to be treated.

* Answer questions forthrightly, but don't volunteer too much information

(you don't want to hang yourself).

* Take notes for yourself.

* Have your programs ready and available.

* Be patient. If you rush the CSHO, he/she will look harder.

* Accompany the CSHO during the entire walk-through.

* Ask questions like, "What are you looking at?"

* Take a photo when the CSHO does.

* Correct the easy stuff immediately.

* Take advantage of the CSHO's experience - "How can that be fixed?"

* Pay close attention at the closing conference.

* Go to an informal conference - get things cleared up.

* Contest what you really don't agree with.

* Notify the OSHA office after you've made corrections or if you're having

problems making them.

* Don't tape-record conversations with the CSHO.

* Don't take anything personally.

* Don't act inappropriately in a professional situation.

* Don't go any farther in the walk-through until you understand the hazard or

possible violation.

* Don't think the CSHO won't find any violations.

* Don't let deadlines pass for corrections, contests, etc.

* Don't be reluctant to call the local office for assistance and interpretations.