Navigating OSHA Facility Compliance

Kelley Lax, PE

Navigating OSHA compliance can be daunting, which can detract from the main goal of OSHA — to keep workers safe.

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Say “OSHA” at a construction site and you’ll likely hear a groan or see an eye roll. It’s a popular misconception that the main goal of the program is to generate red tape, but the OSHA standards have made a significant difference in the safety of workers across America since its inception in 1970. In the 50 years since OSHA was implemented in the United States, the injury rate has dropped from 11 per 100 workers to less than 3 per 100. The fatalities have also dropped from 14,000 to 5,000 per year, even though the number of workers has doubled in that time. Still, there is work to be done. Injuries on the job cause delays and additional costs for mitigation, and can create a culture where employees feel undervalued, leading to turnover.

It’s the responsibility of employers to keep their employees safe. While adhering to OSHA regulations can seem daunting at first, there are ways employers can ensure safe practice and not interrupt their workflow.

Who is Covered by OSHA Regulations?

OSHA regulations cover most private sector employers and their employees, either directly through the federal OSH Act or by an OSHA-approved state job safety and health plan. Workers for state and local government agencies are typically not covered by OSHA, except in those states which require it; neither are the self-employed. A common misconception is that smaller companies are not covered by OSHA. Although some of the reporting rules change depending on the number of employees, all private businesses are required to comply with the regulations.

OSHA Compliance

Aside from the stereotype of construction workers in hard hats and neon safety vests, OSHA regulations apply to a wide variety of business areas. These include:

  • Assessments of existing conditions in facilities such as manufacturing plants, university labs, and water treatment plants
  • During the design phase of construction, ensuring that criteria such as means of egress, loading areas, ventilation, and materials storage are properly planned for to avoid mid- and post-construction changes that are costly and inconvenient
  • Addressing employee complaints and determining employer responsibility before an accident occurs
  • Development of a Health and Safety Plan (HASP) and Emergency Action Plan (EAP)

OSHA Regulations in Action: A Case Study

On March 9, 2018, the Massachusetts governor signed a bill into law requiring counties, municipalities, state agencies, and other state & local workers to be protected under OSHA law. As a result, we were solicited to provide an assessment of a water treatment facility. The facility already satisfied most regulations, as the supervisor had taken the 10-hour OSHA certification course for general industry and had a good working knowledge of the regulations. Our assessment included reviewing a plethora of regulations, as the facility had everything from an in-house chemical lab to cranes to welding equipment, and we identified those areas which were deficient. Examples ranged from the mundane — manholes without a cover, machinery without the proper guards, missing fire extinguishers — to the more critical — a roof leaking onto the electrical generator, a cabinet full of outdated, unlabeled hazardous chemicals. Most critically, the employer was made aware of their responsibility to regularly train employees, so they are aware of the hazards on the job and what to do if they encounter an issue.

As a result of our assessment, the employer was able to prioritize which deficiencies were creating a safety hazard, and which were considered de minimis violations, which have no direct or immediate relationship to safety or health. This effective prioritization of safety considerations helps minimize disruptions to the workflow and keeps workers operating in a safe environment, which, at the end of the day, is what OSHA is all about. Adhering to OSHA regulations doesn’t have to be a headache. With a fire and building safety expert’s help, employers can train their employees and ensure safe practices, keep work moving without delays or hassle, and employees can rest assured their health and well-being is being valued.

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