A seniors’ care facility in Texas has run afoul of OSHA, having been cited for seven serious safety violations following an inspection under OSHA’s national emphasis program for nursing and residential care facilities.

A seniors’ care center in the Dallas, TX, area has been cited by OSHA for seven serious violations under OSHA’s national emphasis program for nursing and residential care facilities. Proposed penalties against Williamsburg Village Healthcare Campus in Desoto, TX, have been set at $46,000.

“Healthcare workers perform an important service and should be protected from preventable injuries while caring for others,” says Stephen Boyd, OSHA’s area director in Dallas. “It is the employer’s responsibility to provide a safe and healthy workplace for its workers and OSHA will hold employers accountable.”

The violations allege failure to:

• Assess whether workplace hazards were present or likely to be present.
• Ensure that each affected worker uses appropriate eye or face protection.
• Ensure that energy control programs consist of appropriate procedures, training and periodic inspections.
• Provide suitable facilities for quick drenching or flushing of the eyes and body.
• Provide a written exposure control plan designed to eliminate or minimize worker exposure to hazards.
• Train and provide workers with information on hazardous chemicals in the workplace.
• Ensure that a written schedule for cleaning and decontamination is based upon the location within the facility and the type of surface to be cleaned.

OSHA conducted a programmed inspection in June 2013 under its national emphasis program for nursing and residential care facilities, in which targeted inspections are geared toward reducing occupational illnesses and injuries from exposure to blood and other potentially infected material; exposure to hazardous chemicals; slips, trips and falls; communicable diseases; ergonomic stressors; and workplace violence.

A WorkSafeBC report into a crash of a 15-passenger van that left three farmworkers dead and 14 others injured in March 2007 has revealed several contributing safety violations.

The 15-passenger van was carrying 17 people, including the driver, when it collided with two transport trucks and overturned on Highway 1 in British Columbia’s Fraser Valley, east of Vancouver.

Factors identified in the crash include:

Overloading of the van, which caused it to be unstable. Poorly maintained tires. Only two seatbelts were available. The driver had the wrong class of driver’s license and was therefore not qualified to be driving that type of vehicle. Poor visibility. Extremely wet road conditions that caused the van to hydroplane.

The incident resulted in the BC government reinstituting random safety checks of vehicles used to transport farm workers. The Liberal government had discontinued that program in 2001 shortly after being elected.

WorkSafeBC says it is considering a penalty against the labour contractor who employed and transported workers to farms throughout the Fraser Valley.

OSHA is proposing nearly $450,000 in penalties against a Minneapolis branch of a sign company after a worker suffered a fatal shock while installing signs and guardrails on Interstate 94 near Menomonie, WI.

The Occupational Safety and Health Administration (OSHA) is proposing $448,000 in fines against a Minneapolis, MN, branch of a sign company regarding the September 2012 electrocution death of a Wisconsin highway worker.

Joseph Janisch, a 34-year-old married father of four children, had been using equipment to install signs and guardrails on Interstate 94 near Menomonie, WI, when it contacted overhead power lines.

OSHA cited 10 violations, including six willful violations, claiming that Highway Technologies, Inc. failed to ensure that equipment wasn’t operated within 10 feet of a power line, failed to protect workers from electrocution hazards and failed to ensure that equipment being moved remained at least six feet below overhead power lines.

Four serious citations allege failure to identify electrical work zones, determine if any part of the equipment being operated would be closer than 20 feet from a power line, train each worker on safe clearance distances from power lines and ensure that each employee understood the training and risks of working near overhead power lines.

“Highway Technologies failed to protect its workers from serious electrocution hazards,” says OSHA Administrator Dr. David Michaels. “Multiple instances of the same violation over a period of time clearly demonstrate a willful failure to comply with basic safety and health standards.”

Headquartered in Houston, TX, Highway Technologies Inc. employs about 1,500 workers in 13 states who install highway guardrails, crash attenuators, barrier walls and signage. Between 2007 and OSHA’s investigation into Janisch’s death, the company has been inspected 10 times by OSHA and cited for nine violations. One of those inspections was initiated based on employee injuries sustained from contacting an overhead power line while installing a power line.

Highway Technologies Inc. has been placed on OSHA’s Severe Violator Enforcement Program.

What’s at Stake?

What does housekeeping have to do with safety? Lots! A clean and orderly workplace is essential to avoid falls, fires and many other kinds of accidents and injuries.

What’s the Danger?

Whether it’s an office, warehouse, workshop or construction site, there are serious reasons for not trying to function in a messy work environment.

Here are some examples:

• Injury or death resulting from a trip or fall.
• Injury or death after being struck by an out-of-place object.
• Injury or death in a fire caused by improper storage or disposal of combustible materials.
• Reduced productivity because of time spent getting around or over someone else’s clutter and looking for proper tools and materials.
• Lack of future work due to a reputation for poor quality and practices.

How to Protect Yourself

Sometimes housekeeping practices are established after a brush with disaster; cleanup seems much more important after a fall or a fire resulting from poor housekeeping. But it should not have to take a close call or an injury before housekeeping becomes a priority. Here are 13 housekeeping reminders that you can easily follow every day.

1. Keep your work area clean, free of clutter, and arranged properly. This means cleaning up spills and leaks quickly and properly too.
2. Dispose of oily rags only in covered metal cans.
3. Keep your tools and equipment clean and well maintained.
4. Report and place out of service any damaged tools and equipment.
5. Inspect electrical cables, cords, plugs and outlets regularly for wear and damage.
6. Keep drawers and cabinet doors closed to prevent tripping hazards.
7. Do your part to keep aisles, exits and entrances are free of obstructions, such as electrical cables, hoses, chairs, and stored materials.
8. Store materials in approved, clearly labeled containers in designated storage areas and remember to stack materials securely so they don’t fall.
9. Never block sprinklers, fire alarms and fire extinguishers.
10. Only smoke in designated areas and use the ashtrays provided.
11. Clean up after yourself in the breakroom. Don’t leave trash on the tables, clean your dishes, and remove your old food from the refrigerator at least weekly.
12. Same thing goes in the washrooms too – help keep them clean and dry.
13. Report safety hazards and housekeeping concerns immediately.

Final Word

Good housekeeping is not a special activity for when visitors are coming. It’s a way of life for a safe workplace. Take responsibility for workplace housekeeping and do your part to help protect yourself and your co-workers from fires, falls and other serious incidents.

What’s at Stake?

The abrasive wheel grinder is a common – and dangerous – piece of machinery. When working with grinders and other power tools, you must think about safety all the time to prevent being cut, drilled, sliced, diced or crushed.

What’s the Danger?

Revolving at 10,000 surface feet per minute (sometimes more), grinders are a threat to hands and fingers. But that’s not all. Flying debris, dust and fumes, and the noise of the machine itself endanger your eyes, ears and respiratory system.

Workers have been killed when using improper grinding discs. They can fracture, sending fragments into nearby workers. Other causes of disc fracturing include:

• using too much pressure on the tool;
• using a cracked or chipped wheel; and
• using a machine with an operating speed faster than the RPM rating of the disc or wheel.

Consider the following incident. An employee was grinding on a pipe stand with a hand grinder. As the employee was grinding the pipe stand; the grinding wheel exploded and hit the face shield, causing damage to the face shield and hitting the employee in the right eye and face.

The incident investigation revealed:

• The grinding wheel that was being used was not the correct size for the job.
• The never-before-used wheel was not tap or ring tested and had a crack from shipment.
• The grinder did not have the required guards in place.

How to Protect Yourself

When operating grinders, always use the recommended personal protective equipment (PPE), including safety glasses, gloves, a dust mask and appropriate hearing protection. Also, avoid wearing loose clothing that could get caught in the machinery.

Besides PPE, proper guarding is an important safety feature for those working with grinders. On stationary grinders, wheels should be guarded with a heavy metal enclosure. There should also be an adjustable guard over the front of the wheel for protection as the wheel diameter gets smaller. Work rests to support the pieces you are working on should be installed on the front lip of the enclosure, within 1/8 inch of the grinder.

Portable grinders should have guards on the end that overlap the disc to prevent kick-back. They should also have an adjustable hand rest to maneuver and stabilize the grinder. When working with portable grinders, remember that air operated grinders run at a higher speed, and electrical grinders have electrical hazards to consider.

Other tips to remember and follow:

1. Check that your work area is clean, dry and well lit.
2. Inspect the equipment.
   1. Is the grinder steady or mounted securely?
   2. Is the wheel the correct size for the machine’s size and speed?
   3. Is the wheel evenly worn?
3. Test the wheel by tapping it with a light non-metallic tool.
   1. A clear ring means the wheel should be fine.
   2. A thud means the wheel may be cracked and shouldn’t be used.
4. Ensure all guards and rests are in place and the electrical motor cover is secure.
5. Check the power source is properly grounded and that the cord and connections are not damaged.
6. Ensure dry grinding operations are connected to an exhaust system.
7. Next, check your posture. Make sure you can stand and work in a balanced position and have firm control of the tool without overreaching.
8. Finally, stand off to the side and test the wheel to make sure that it is operating correctly.

Final Word

Grinding can be a dangerous task. Protect yourself by wearing the proper PPE, using machine guarding and following a safety checklist.

Safety Talk

What’s at Stake?

Working with hazardous chemicals is a known cause of illness or injury to workers. A Safety Data Sheet (SDS) must be provided by the supplier for any substance classified as hazardous. An SDS contains a lot of vital, specific information on how to store, handle, and work with that substance. The information is essential for all staff working with a hazardous chemical as it gives more detail than the chemical’s label.

The SDS for each chemical must be easily available to workers at all times and can either be a paper copy or electronic copy, provided staff can access it when needed, such as on their cell phone or laptop.

What’s the Danger?

A Safety Data Sheet is written for everyone who works with the substance. This means a lot of the information can be quite technical or not relevant to all workers. This can lead workers to think the SDS does not apply to them or it’s too technical to read, so they don’t read it.  Safety Data Sheets are designed to be easy to read, with 16 standardized sections. And since many sections apply to most workers, failure to read the SDS is risky and can lead to illness and injury. Employers have a responsibility to train workers on how to read an SDS and how to work safely with chemicals.

Hazards

• Lost or out of date SDS
• Workers do not know what risks and precautions they need to take
• Complex information leads to misunderstanding

How to Protect Yourself

3 easy ways to use Safety Data Sheets

1.  Know the SDS

• Know where the SDSs are kept and how to get to them.
  • How to access electronic version.
  • Where the paper file is kept.
• Make sure your supervisor talks you through relevant SDSs when you start work or first start using a hazardous substance.
• Check the chemical label.
  • This gives you a heads up there is more you need to know.
• Attend training updates on working with specific hazardous substances.

1. Read with a purpose

• There are 4 main types of information on each SDS.
  • Identification
    • Of the product and supplier.
  • Hazards
    • Physical e.g. fire, and to health, e.g. breathing difficulties.
  • Prevention
    • How to work safely, reduce or prevent exposure.
  • Response
    • Appropriate responses in various situations (e.g., first aid, fire, accidental release).

1. Important details for everyone

• Check the name of the chemical (Section 1).
• Know what it is typically used for, and when it should not be used (Section 1).
• Know the potential hazards (Section 2).
• Read safe handling and storage instructions (Section 7).
• Know what to do in an emergency (Sections 4, 5 and 6).
• Date of latest SDS revision (Section 16).

Final Word

It is vital you have as much information as possible about chemicals you are working with.  Your employer must make sure employees are aware of the specific information they need and can easily get that information when needed. Regular training and updates on the chemicals used and stored at the worksite, complement the information provided in an SDS.

Safety Talk

What’s at Stake?

Chemicals are present everywhere. We encounter them every day, often without even knowing it. But, not knowing what chemicals are present at work and how to manage them safely, puts lives at stake.

What’s the Danger?

Chemicals come in many forms and can cause death, cancers, respiratory, organ damage, and birth defects, if misused. Some may start fires, cause explosions, or damage the environment. Because of their dangerous nature, safety and health laws require suppliers and workplaces to label and attach information about all hazardous products. Labels carry the product name, related hazards, safety measures and more.  The absence or damage of labels can lead to injury, illness, and catastrophic events.

Factors contributing to chemical accidents include:

• No product identifiers such as brand, chemical, common, generic and trade names of the product to inform users what the substance is. This can easily cause someone to use the wrong chemical. Example, bleach can be mistaken for water.
• In the event of a chemical accident, further damage can be experienced if there is no supplier identifier. The supplier identifier lists the name, address and telephone number of the manufacturer or importer to be contacted for advice.
• The absence of a signal word (either Danger or Warning) that will alert and show the severity of a potential hazard to a user.
• The absence of hazard statement(s) describing the hazardous nature of a product. Example “poisonous; avoid contact with mouth.”
• No precautionary statement(s) that describe measures to prevent or minimize the effects of a hazard. Example, “use eye protection.”
• No supplemental label information on details about potential hazards and precautions not included in the label.
• Not understanding pictogram(s). Pictograms are images inside a red square which gives users an idea of the type of hazard in a product. The following describes 9 pictograms:

1. “Flame” pictogram warns about liquids, gases, mixtures, solids or sprays that can start a fire or explosion.
2. “Flame over a circle” is for oxidizing gases, liquids and solids that combine with oxygen to increase fires and explosions.
3. The “gas cylinder” shows gases under pressure such as compressed gas, liquefied gas, refrigerated liquefied gas, and dissolved gas, all of which can cause an explosion, severe cold, burns and injuries.
4. The image of a “corroding hand and metal” represents corrosive products that damage metals and irritates the eyes and skin.
5. “Exploding bomb” shows substances and mixtures that react alone to cause fires and explosions.
6. The “skull and crossbones” is for toxic products that must never be inhaled or allowed to touch the skin and mouth.
7. The image of a “human head and shoulders” represents chemicals that can easily cause death, cancer or damage the respiratory/reproductive systems, skin and body organs.
8. The “exclamation (!)” is used to show high toxic risk, skin/eye allergies and organ damage.
9. The image of the “dead fish and dead tree” are substances that may cause harm to the aquatic environment.
   1. This is a non-mandatory pictogram under OSHA, because it deals with environmental hazards.
   2. Environmental hazards are regulated under the EPA or Environmental Protection Agency.

The absence of any of the above label information, required to be in English at a minimum, can result in accidents.

How to Protect Yourself

• Always check for a label before using any product.
• Follow all the instructions on the label and SDS.
• Learn to identify pictograms.
• Attend all training provided by your employer.
• Use all recommended PPE.
• Ask questions when in doubt.
• Avoid unlabeled products and do not use unreadable labels. Report these to your supervisor so a new label can be created and used.

Final Word

Chemicals can be dangerous to your safety, your health and the environment. Always read labels and pictograms for information on safe handling, use, and storage.

Plant issued $62,350 in proposed penalties. OSHA alleges that its inspectors found instances of improper transfer and storage of flammable liquids, lack of specific lockout/tagout procedures and training to prevent the unintentional startup of machinery during maintenance and a lack of hearing protection. Other alleged hazards include inadequate respirator training, fit-testing, medical evaluation, inspection and maintenance, unguarded grinders, blocked access to electrical boxes, electrical equipment not safely maintained in hazardous locations and an accumulation of combustible dust in a work area. Further, OSHA says the plant lacked a written program and training for employees required to enter confined spaces, failed to inform workers of the presence of asbestos-containing insulation on steam pipes and failed to provide the Hepatitis B vaccine and training to workers whose duties involved exposure to blood or other potentially infectious materials.

[Worldcolor Buffalo, Depew, NY, Feb. 24, 2010].

Fines totaling $48,000 have been proposed after inspectors found alleged repeat and serious safety violations. The repeat citations allege that scaffolds lacked guardrails, weren’t fully planked, did not have toe boards installed and contained an area underneath that was not barricaded. The other repeat citations allege that employees did not have safe access to scaffolding, did not wear protective headgear and hadn’t been trained to recognize hazards associated with scaffolds. Serious violations include allegations that employees were allowed to use a scaffold that had platforms extending beyond supports, was not secure and was not erected under the supervision of a competent person. A fourth serious citation alleges a tripping hazard created by debris and loose bricks.

[Mario Rivera-Delgado, doing business as Big M Masonry, Anniston, AL. Release Number 07-1493-ATL (305), Oct. 15, 2007].

Fines totaling $134,000 have been proposed. OSHA issued three willful citations alleging that the company failed to provide its employees with adequate fall protection, safe access to scaffolding, and fully-planked work scaffolding. Four repeat citations were also issued. They allege failure to maintain a safety and health program; failure to erect scaffolding under the supervision of a competent person; failure to adequately train employees working on scaffolds; and extending scaffolding beyond 18 inches of supports. Serious citations allege hazards including failure to protect employees from head injuries due to falling objects, and allowing employees to place ladders on top of scaffolding.

[Wally Cilulko, doing business as AJC Restoration Inc., Chicago, IL. Release Number 07-1431-CHI, Oct. 1, 2007]

OSHA opened an investigation after a diver drowned as a result of a lifeline becoming entangled in the water pump of a 500,000 gallon in-ground water tank. OSHA cited the company for willful failure to conduct a safety and health assessment for surface and underwater conditions when planning diving operations and failure to brief dive team members of any hazards or environmental conditions that may affect the safety of the diving operation. Serious violations alleging entry into a confined space without verification that it was safe for entry; failure to ensure that the supervisor verified all tests were conducted and that all equipment and procedures were in place in accordance with confined space requirements; and failure to develop and document procedures for the control of potential hazardous energy, were also cited. Proposed penalties total $64,000.

[International Diving Services, Arlington, TX. Release number OSHA 08-1656-DAL, Nov. 10, 2008]

OSHA says an inspection conducted under its Site Specific Targeting Plan found numerous instances of unguarded machinery; no hazardous energy control program, training and equipment to prevent the accidental start-up of machinery; unguarded live electrical parts; improper storage of compressed gas cylinders and fall hazards related to a lack of fall protection, inadequate ladder safety, uncovered floor openings and unguarded open-sided work platforms and stairways. Other alleged hazards include no confined space training program for employees whose duties involve entering sauerkraut tanks; no hearing conservation program for employees exposed to excessive noise levels and a lack of training in fire extinguisher use and hazards associated with early stage firefighting.

[Great Lakes Sauerkraut Co. LLC., Shortsville, NY. Release number 09-175-NEW/BOS 2009-046, Feb. 24, 2009].

An OSHA construction safety task force that descended upon 46 New York City construction sites during two weeks this past summer found that fall hazards topped the list of cited violations.

A dozen OSHA inspectors conducted 96 safety inspections and issued citations to 60 contractors for 129 health and safety violations including fall hazards (39), electrical safety (29), scaffolds (17), cranes and rigging (13) and welding/gas (10). Other citations were issued for violations involving PPE, tools, material handling, concrete, hoists, stairs and ladders.

The sites were randomly selected to encompass a cross-section of high-risk construction activities, including tower crane operation, high-rise construction, poured-in-place concrete operations, steel erection, and gutting and total rehabilitation of buildings (called gut-rehab for short).

“These violations are consistent with the types of hazards we find on far too many jobsites and cannot be written off as the inevitable by-products of an inherently dangerous profession,” says Richard Mendelson, OSHA’s area director in Manhattan.

OSHA followed up with an early-August construction stakeholder safety meeting with industry representatives, in which trends in construction safety violations were analyzed. OSHA recommended that all parties involved in New York City construction work to “raise the bar on safety.”

A second round of concentrated construction inspections will be conducted in the future, OSHA promises.

Proposed fines totaling $187,150 have been issued to an industrial oven manufacturer following safety and health inspections. Two willful citations allege that the company failed to provide adequate fall protection and to evaluate hazards in confined spaces. Thirty-six serious citations allege machine guarding, fall protection, electrical, respiratory protection, fire extinguisher, welding and bloodborne pathogens issues.

[International Thermal Systems, LLC, Milwaukee, WI. Release Number 07-1257-CHI, Sept. 4, 2007.]

OSHA says an inspection revealed that employees of a Georgia manufacturing company were being exposed to fire, electrical and tripping hazards. The inspection brought citations alleging hazards involving material handling, machine guarding, lockout/tagout and forklift operations. Alleged health violations include hearing conservation issues, storage of flammable materials, PPE and hazard communication program deficiencies. Penalties totaling $137,000 are being proposed.

[Overhead Doors Corp., Athens, GA. Release number 08-1233-ATL (212), Sept. 12, 2008].

The Somerset Mill in Skowhegan, ME, was issued repeat citations for unguarded open-sided floors and platforms, unguarded in-running nip points on paper machines, defective guarding of a saw, uncovered revolving shaft couplings and an unguarded conveyor drum. Fourteen serious citations were also issued for alleged hazards including fall hazards, unguarded floor and wall openings, work areas not kept in a sanitary and orderly condition, unsecured materials in storage racks, inadequate work space around electrical equipment, ineffectively closed electrical panel openings, a jagged railing and unguarded moving machine parts.

[S.D. Warren Co., Skowhegan, ME, Oct. 2, 2009]

OSHA conducted an inspection late in 2008 and found several alleged violations, including unguarded machinery, electrical hazards, fall hazards, an unmarked exit door, inadequately illuminated exit routes, confined space hazards, unsanitary eyewash facilities, poor housekeeping and no assessment of the workplace to determine what PPE workers would need. In addition, employees were allegedly exposed to crushing, struck-by and other hazards from unenclosed counterweights on a conveyor and an improperly maintained conveyor emergency stop cable.

[Domtar Maine Corp., Baileyville, ME. Release number 09-595-BOS/BOS 2009-154, June 9, 2009]

OSHA conducted an inspection after a worker crushed his hand between a rotating unguarded drum drive wheel and a pipe. OSHA cited the company for failure to provide machine guarding on lathes, drum drive wheels and saws, failure to provide fall protective equipment, failure to protect workers from electrical hazards, and failure to provide training for forklift operations and hazard communication.

[Industrial Pipe Fittings LLC (IPF), Corsicana, TX, Oct. 9, 2009]

Worker faces proposed fines of $182,000. OSHA opened an investigation in September 2009 in response to a referral made by Maryland Occupational Safety and Health after numerous serious and willful violations were issued at a similar processing facility in Maryland. Numerous serious citations allege hazards involving industrial trucks, falls, PPE, machine guarding, electrical equipment, process safety management, respirators and emergency response.

[Allen Family Foods Inc., Harbeson, DE, March 11, 2010]

OSHA claims employees were exposed to the dangers of falls, crushing injuries, burns, hearing loss, lacerations, amputations and electrocution. Among the alleged hazards were defective forklifts, employees working under raised or unstable loads, wet floors, clogged floor drains, missing guardrails, lockout issues, damaged lifting slings and unguarded machinery. Proposed penalties totaling $117,250 have been issued.

[Atlantic Pipe Corp., Plainville, CT. Release number 08-1283-BOS/BOS 2008-255, Sept. 15, 2008].

OSHA initiated an inspection in response to a formal complaint and cited six willful and eight serious violations. Alleged willful violations include failure to provide adequate energy control procedures and a hearing conservation program. The serious violations allege a lack of machine guarding, failure to conduct a hazard assessment of the workplace to determine the need for PPE, failure to provide PPE for workers and failure to provide and use PPE when working on or near energized electrical equipment. Other-than-serious violations were cited for alleged recordkeeping issues.

[Chapman Printing Co., Huntington, WV, Dec. 18, 2009].

Proposed penalties of $134,900 have been issued to a company following OSHA inspections. They include a willful citation for failing to ensure the use of hearing protection by employees exposed to high noise levels. The other violations, including 47 alleged serious citations, are too numerous to detail, but OSHA says employees were potentially exposed to hearing loss, burns, cuts, tripping/fall hazards, amputation, crushing, fire, explosion, asbestos, the possibility of being struck by forklifts and the potential for being overcome by toxins or an oxygen-deficient atmosphere.

[Boston Felt Co. Inc., Rochester, NH. Release Number 07-1150-BOS/BOS 2007-224, Aug. 20, 2007].

OSHA responded to an employee’s complaint and determined that exit routes were obstructed by stock and equipment. Also, OSHA alleges that an exit route was too narrow for passage, stacked material prevented employees from identifying the nearest exit, access to fire extinguishers was blocked, boxes were stored in unstable tiers eight feet high and workers were not trained in the use of fire extinguishers. Similar violations were cited at other Home Goods stores in 2006 and 2007, leading OSHA to issue five repeat citations for the latest alleged violations. Additional serious citations were issued for a defective fire alarm box, a missing exit sign, electrical hazards and inadequate chemical hazard communication.

[Home Goods, Long Island, NY, Jan. 14, 2010]

Newmarket Stucco Supplier Fined $55,000 for five OHS violations discovered during a routine inspection of a construction site, including not ensuring that workers wore protective headgear at all times, lack of fall protection and failure to ensure access and exit from a scaffold work platform. [Architechniques Pro Corp.]

If you have multiple facilities, you run the risk of repeat violations. Here’s a notice to give site managers to manage the liability risks.

The purpose of this Briefing is to notify you about the risk of being cited for repeat violations by OSHA and what we need you to do to help us manage this risk.

Background
As you know, [name of company] has [number] facilities across the U.S. OSHA inspectors may visit any one of these facilities at any time and issue a citation if they spot a hazardous condition. This can lead to fines, work stoppages and other penalties.

A repeat violation can occur when a company is cited more than once for the same violation. Repeat violations are a big concern because they can lead to fines up to $70,000, subject the company to further inspections under OSHA’s strict new enforcement program and damage its reputation. 

How Repeat Violations Can Occur
Repeat violations can occur when an inspector returns to a facility and finds that the problem he cited before hasn’t been fixed. But a company, like ours, that has many facilities can also get hit with a repeat violation if the same violation is found at more than one facility.

In other words, a citation at any one of our other facilities counts as strike one against all the others. And as far as repeat violations are concerned, you only get two strikes before you “strike out.”

What We Can Do To Prevent Repeat Violations
What this means is that when one facility gets cited for an OSHA violation, we’re all vulnerable. So we need to work together to protect the company. Some of the common measures we intend to take:

1. SHARE DATA. If your facility is inspected by OSHA, immediately send a copy of the inspection file including, but not limited to, notes from the opening and closing conferences, correspondence, settlement agreements, inspection notes and photos and steps taken to correct any violations, to the central office.
2. CREATE A COMPLIANCE COMMITTEE. A joint committee comprising representatives from each of the company’s [number] facilities will be formed shortly and shall meet monthly by conference call. Appoint yourself, a compliance officer or other designee to serve on this committee who will be responsible for reporting on OSHA-related activities at your site.
3. ISSUE MONTHLY REPORTS. Headquarters will coordinate compliance efforts among the facilities and issue a monthly report summarizing new initiatives, inspection results and other OSHA developments from each facility.