Unit 2 Assesment BOS 3525
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Unit II Assessment
BOS 3525
2
Unit II Assesment
To begin, as soon as we receive notification of the follow-up the of OSHA complaint
informing that the complaint became formal, I would schedule an emergency meeting with all
facility managers, with special and required attention to the managers in charge of the work area
where the complaint was generated. I would make sure that they are aware of the seriousness of
the allegations and the imminent possibility of the OSHA visit, considering that 60 to 70 percent
of OSHA Inspections are triggered by employee complaints alone (
How to Survive an Osha
Inspection
, 2004). We would discuss the complaint and what further steps need to be taken,
firstly if the hazards that generated the complaint exist and have an action plan to eliminate or
reduce them. In this case, because the complaint generated was in the welding area, also I would
have made sure to complete a walkthrough with a special concentration of the in that area and
also all adjacent ones.
I would review the policies and procedures. Make sure required PPE and
engineering controls are available and in compliance, and that air sampling was completed.
Considering that there might little to no time to fix all issues, I would have a plan with leadership
that as soon as we receive the visit from the compliance officer during the opening meeting, all
managers will be notified to walk-through their areas, before the compliance officer arrives at
their areas.
I would take the following steps as soon as the compliance officer leaves:
Heavy haze in the welding area
- I would make sure we have available welding fume
extractors available in the welding area. I would retrain affected employees, reinforce the
importance of the use of the extractors by making it part of their hot work permit. If any
3
safety device required is not available, they must contact management and the work
cannot be done.
Half-Mask Air Purifying respirator
s
with full beards
- For individuals wearing half-
mask air-purifying respirators, a re-training will be completed with a focus on the
importance of not having full bears proper sealing will protect against hazards. Also, a fit
test will be completed and documented for those affected employees.
Use of chemicals that could injury the eyes and no eyewash -
For the chemicals being
used that could cause injury to the eyes, I would review the SDS and provide
recommended PPE when chemicals are being used, chemical retraining would also be
conducted. Because there is no emergency eyewash, I would provide a portable eyewash
with required training until one can be installed in that area.
Eyewash covered in dust -
The eyewash covered in dust will be immediately sent to
clean, change dust caps and any other required part that might be in bad condition,
include it in a complete weekly inspection, and create a list of all facility eyewash/safety
shower locations to avoid this to happen again.
Chemicals that can be absorbed through the skin and no gloves being used –
I
would verify the SDS and provide required PPE when chemicals are being used. training
will be also conducted
Maintenance being performed inside a press with no lock-out tag-out applied –
I
would investigate if there was an existing process of lockout tag out and if employees
working in that machine were trained. I would also try to get root cause analysis if
employees were trained but rules were not being followed. Training will be conducted
and include part of the corrective action periodic behavioral observations in that area
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No written lock-out tag-out program available at the time of inspection
– develop
and implement a lockout tag out the program and trained all affected employees
Welding operation performed near flammable materials and no fire watch is
present
– Affected workers will be trained in the hot work process; the fire watch also
will be trained on the fire extinguisher. the hot work permit will include the verification
of the Firewatch present for the work to continue
No record of training of fork truck driver
– All fork truck drivers will be trained and
evaluated to be authorized to drive the equipment
Extension cords stretched across walkways
– the extension cord will be plug-in the
room intended to be used. In the case that is needed to complete a work it should be
taped on the floor with safety cones around to let pedestrians know, however, this only
should be a quick fix, not meant to be there
3 containers with no label present on any of the containers
– Employees will be
trained on hazard communication, all containers without labels will be discarded and
secondary containers will be label as appropriate
The employee could not find SDS for a chemical being used
- all employees will be
trained on hazard communication including hands-on training on how to find chemicals
on the SDS database
For the things that I could have fixed during the walkthrough to result in a penalty
reduction the ones that I could try to fix is provide chemical resistant gloves to the employees for
5
the things that I could quickly fix during the walkthrough to result in a penalty reduction there is
not much to be done but I would have provided chemical resistant gloves to the employees that
were using chemicals that could be absorbed through the skin.
Make sure that employees that
were using chemicals that could injure their eyes were wearing safety glasses, stopped the work
that was being done in the press that didn’t have a lockout tag out, and make sure that they do
one do the work can be completed.
Stope the welding process that didn’t have a Firewatch
present until one was present.
Removed the extension cords that were stretched out in the
walkway, Discard the containers with chemicals that didn’t have a label, and educated the
employee that couldn’t find the SDS on how to do it.
All the observations that the compliance office pointed out could have been avoided if the
facility had a strong safety culture, management compromise, proper training, and continuous
internal audits.
Employers and their facilities shouldn’t wait for this moment to come to fix
issues, they should be ready all the time and continuously improving. The reason why OSHA
gives citations is that as a Federal Agency their main object is to ensure that workers are being
provided with a safe work environment, penalties and citations are ways to make employers
understand how serious and important is to protect employees and avoid injuries and fatalities.
6
References
How to survive an osha inspection
. (2004, March 11). EHS Today.
https://www.ehstoday.com/health/article/21910361/how-to-survive-an-osha-inspection
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