Fall 2004 - National Ready Mixed Concrete Association

safety first
The OSHA Inspection –
Are You Ready
By Thomas Harman, M.S., CSP
Director of Safety Compliance, NRMCA
When OSHA shows up at a ready
mixed concrete plant, and the
compliance safety and health
officer (CSHO) shows his/her credentials,
some plant managers are surprised. Surprise
turns into anxiety when the CSHO begins
asking to see injury/illness reports, training
records, job procedures — in short all the
safety and health items mandated by the
Occupational Safety and Health Act of 1970
that operators must maintain. Ready mixed
concrete plant operators can prepare for the
inspection by understanding the audit
process and ensuring compliance as it relates
to our industry.
The OSHA audit process is divided
among three parts: the opening conference,
the inspection and the closing conference.
During the opening conference, the CSHO
presents credentials from the Department of
Labor and communicates the scope of the
inspection; this provides an opportunity for
the employer to ask any questions about the
inspection. For example, a complaint may
have initiated the review. Similarly the
inspection may be a random programmed
inspection or health inspection.
CSHOs first view records and reports.
Employers must maintain the OSHA 300
log and summary for five years. The inspector
may also ask to see the supplementary
injury and illness information, which is a
more detailed description of the injury or illness
event. Ready mixed concrete employers
also must train employees in hazard communication,
confined space work, lock out and
tag out, and at many companies, respiratory
protection.
The OSHA representative then starts the
walk-around portion of the inspection.
He/she may go to any portion of the plant
and may privately interview employees along
the way. The inspector will likely ask
employees what types of training the
employer has provided, such as how to operate
a fork lift or how to safely clean out a
mixer drum. The inspector is looking for
validation that employees have received
training that is appropriate for their type of
work.
An employer representative must accompany
the CSHO at all times during the
inspection process. When the inspector takes
notes or pictures, or takes a measurement,
then the representative of the employer
should do the same. Therefore, the employer
agent needs a note pad and pen, a measuring
device such as a tape measure, and a camera.
This ensures that everyone has a clear understanding
of the condition should citations be
issued. In the event that the CSHO conducts
health sampling, as in the case of testing
for exposure to respirable crystalline
silica, then the employer should collect an
air sample, too.
Optional equipment for the employer
rep is a personal dust pump. This ensures
the air sample is valid; the same exposure
level should be seen in each of the two samples.
During the closing conference, the
CSHO reviews findings or recommendations.
The inspector also indicates the conditions
and/or practices that are likely to be
cited. If the employer disagrees with the
inspector’s findings, then the closeout provides
an opportunity to appropriately
address the dispute.
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38 ı FALL 2004