Cooperate
and Participate or be on OSHA'S INSPECTION LIST for 1998
Under
the new Enforcement-based Cooperative Compliance Program (CCP), Employers
with 60 or more employees have until January 30, 1998 to respond to letters
sent to them by OSHA. This falls under the 1998 Voluntary Safety and Health
Program Management Guidelines; Issuance of Voluntary Guidelines. .
OSHA sent out letters
to employers who were on their primary inspection list for a comprehensive
safety and health inspection. The employers selected are a result of an
OSHA survey that collected workplace injury and illness data from employers
with more than 60 employees in manufacturing and 14 other selected industries.
Do you know if
you are on the list? The following is the list provided by OSHA of the
Industries selected and their SIC Codes. If you are on this list, you
are subject to this new CCP program under OSHA. According to OSHA, the
program is voluntary however, if you elect not to participate, your Company
will be a target for full OSHA inspections this year and remain on their
Primary List.
| SIC
Code |
Industry |
| 20
- 39 |
Manufacturing |
| 783 |
Ornamentul
shrub and tree services |
| 4214 |
Local trucking
with storage |
| 4215 |
Courier services,
except by air |
| 4220 |
Public warehousing
and storage |
| 4491 |
Marine cargo
handling |
| 4580 |
Airports,
flying fields, and services |
| 4783 |
Packing and
crating |
| 4953 |
Refuse systems |
| 5051 |
Wholesale
metals services centers and offices |
| 5093 |
Wholesalers
for scrap and waste materials |
| 5140 |
Wholesalers
for groceries and related products |
| 5180 |
Wholesalers
for beer, wine, and related beverages |
| 5210 |
Retailers
for lumber and other building materials |
| 8050 |
Nursing and
personal care facilities |
When you agree
to join the CCP program, you will not be subjected to an OSHA inspection
until May 4th 1998 or later. You will also be required to agree to certain
conditions of the agreement as follows:
1. Identify and
correct safety and health hazards in your workplace
2. Actively involve
your workers in the identification and abatement of hazards in the workplace,
as described Section XVI of the compliance directive provided to you
by OSHA. Workers include regular workers, management, temporary, and
leased employees.
3. Implement
a comprehensive safety and health program based upon the principles
set forth in the 1998 Voluntary Safety and Health Program Management
Guidelines; Issuance of Voluntary Guidelines.
Brief
outline of the Safety and Health Program Guidelines:
A program which
provides systematic policies, procedures, and practices that are adequate
to recognize and protect workers from occupational safety and health
hazards.
An effective program includes provisions for identification, evaluation,
and prevention or control of general workplace hazards, specific job
hazards, and potential hazards, which may arise from unforeseeable
conditions.
An effective program is pro-active in preventing injuries and illness
beyond compliance issues.
A written program providing guidance and outlining how to identify
hazards and prevent injuries and illness, will assist in ensuring
clear communications and consistent and fair application of the rules
including the policies.
4. Actively involve
your employees in the comprehensive safety and health program.
5. Work to significantly reduce your LWDII rate (Lost Workday Injury
and Illness Rate).
6. Fill out the
OSHA agreement and return it by January 30, 1998.
7. Send OSHA,
once a year, information from the OSHA 200 annual summary form (the
injury and illness log) during the two years of the program.
If you have 100
or fewer employees, there is an additional option available:
You may elect to
join the CCP as describe above and commit to using a full service on-site
visit from the State Consultation Program, and meet the obligations described
above.
You must inform
the Consultation Program Manager that your request has been made as a
participant of the OSHA CCP.
You agree to involve
your employees in the consultant's on-site visit, and show the employees
the consultants report describing any hazards found, result of any workplace
monitoring, the abatement and plans for abatement of the hazards.
By electing the
use of a consultation program you will placed on a lower inspection priority
(tertiary) list, which will OSHA only inspect 10% on this list. CCP inspections
are not scheduled until the consultation manager has advised OSHA they
have completed the abatement of the identified hazards.
Your Employment
Risk Solutions, Inc. (YERS) has developed a very comprehensive Safety
and Health Program as part of their Compliance Pro (A Trademark) software
Program, which not only provides the recommended guidelines but also exceeds
them. The Program provides graphic illustrations on proper lifting techniques,
transfer of objects, ergonomics and workstations, avoiding eye fatigue,
repetitive motion injuries, and nutritional guidance in the Health and
Wellness section.
YERS recognized
the lack of sound guidance in compliance issues for employment and labor
laws, including safety and health available to the small business community.
YERS developed Compliance Pro to bring the small business community a
valuable resource and tool which provides guidance in all theses areas
and written in practical and understandable language. The CCP program
is not available to businesses with less than 60 employees, even though
an employer with 15 or more employees falls under Title VII and OSHA regulations.
OSHA is starting to recognize the need for assistance to the small business
community, however has not implement any significant programs that we
are aware of.
YERS programs are
currently endorsed by The Independent Bankers Association of Texas and
are been utilized by such companies as ABBSeatech, IKON Office Solutions,
A&B Parts Group a Division of Delco Remy and The Greater Dallas Chamber
of Commerce.