OSHA POSTER

Near Hit/Miss: A Near Hit or Near Miss is an undesired event that, under slightly different circumstances, could have resulted in harm to people, damage to the environment or property, or loss to process.

First Aid: A treatment for a work related injury or illness that does not ordinarily require medical care, regardless of who provides treatment. OSHA considers only the following types of treatments as first aid cases (any other type of treatment is to be considered a Recordable Incident): 1) Using a non prescription medication at non prescription strength ; 2) tetanus shots; 3) cleaning flushing or soaking wounds on the surface of the skin; 4) Using wound coverings such as bandages, butterfly bandages and steri-strips; 5) hot/cold therapy; 6) non-rigid support; 7) temporary immobilization devices while transporting; 8) drilling of nail; 9) eye patches; 10) removing foreign bodies from eye by using only irrigation and cotton swab; 11) removing splinter from other than eye by irrigation, tweezers or other simple means; 12) finger guards; 13) massages; 14) drinking fluids for relief of heat stress.

OSHA Recordable Incident (RI): Any work related injury or illness that results in death, days away from work, restricted work, transfer to another job, medical treatment (except first aid), loss of consciousness, or significant injury or illness diagnosed by a physician or other licensed health care professional.

• Days Away From Work Case (DAFWC): Any work-related injury or illness where the employee could not have worked on any day after the injury or illness, irrespective of whether there was scheduled work, or when a physician or other licensed health care professional recommends that the worker stay at home but the employee comes to work anyway. Each full calendar day is counted, not including the day of injury, even if the employee was not scheduled to work that day (including weekends and holidays).
• Restricted Work: Any work-related injury or illness as a result of which (1) you keep the employee from performing one or more of the routine functions of his or her job, or from working the full workday that he or she would otherwise have been scheduled to work; or (2) a physician or other licensed health care professional recommends that the employee not perform one or more of the routine functions of his or her job, or not work the full workday that he or she would otherwise have been scheduled to work.
• Medical Treatment: Treatment for a work-related injury or illness beyond first aid, regardless of who provides treatment. Medical treatment does not include first aid treatment even though provided by a physician or registered professional personnel, observation, counseling, or diagnostic procedures.
• Occupational Illness: Any abnormal condition or disorder, other than one resulting from an occupational injury, caused by exposure to environmental factors associated with employment. It includes acute and chronic illnesses or diseases, which may be caused by inhalation, absorption, ingestion or direct contact.

This program explains protocol that Atwell employees shall follow before, during and after an OSHA inspection. This policy has been developed to help us efficiently and uniformly address OSHA inspections by:

· Displaying a positive, professional image.

· Demonstrating the value that safety & health plays in our work culture.

· Aiding in the defense of any citations issued as a result of an inspection.

· Taking full advantage of our rights under the OSHAct.

· Limiting company liability.

Contact the Safety Department.

As soon as you become aware of an OSHA inspection on your jobsite, immediately contact the Safety Department.

Participate in the opening conference.

Upon formal arrival at the jobsite, the OSHA inspector should ask to meet with the site controlling contractor representative (if one is present). Once the inspector identifies him/herself, an opening conference is held to explain the purpose of the visit and the scope of the inspection.

As a subcontractor, we have the right to attend this opening conference to see if the inspection will involve us in any way and if so, why. It is for this reason that the controlling contractor must be aware of our policy so that we can be included in this aspect of the inspection. At that time you can explain that Atwell has an OSHA Inspection Policy which requires you to notify the Safety Department.

Keep the inspection focused.

Show the inspector only what s/he wants to see in your area. If s/he is only interested in surveying a particular area, operation, piece of equipment or process, take him/her directly to it. If s/he is there for a specific reason, stay focused on that reason and direct the inspector only to areas that have to do with that reason. A direct route exposes the inspector to less of our work area, thus decreasing our overall exposure to the possibility of citation.

Walk with the inspector.

Take an employee with you. Whenever possible, immediately correct any problems or hazards that the inspector may point out – but do so without admitting guilt or responsibility for the hazard. You can use general statements like, “I can see what you are saying.” or “I understand that concern.”

We can still be cited for alleged hazards that you correct, but the monetary penalty can be reduced where “good faith” is shown. Demonstrate or explain any efforts that you have made to control or eliminate the alleged hazard(s). Note that an inspector does not have the right to open or inspect your vehicle or job trailer without permission, unless it is left open and in plain view.

Be proactive.

Don’t wait for OSHA to identify hazards on the jobsite. Take initiative to identify hazards on your own and either correct them yourself or seek corrective action through the site GC, other subcontractors or the Safety Department. Know what OSHA will be looking for/at in your work area and focus on (but don’t limit yourself to) these items. Be familiar with OSHA’s most frequently cited citations for our trade.

Be vigilant.

Understand that in most cases, OSHA will see you before you become aware of their presence. Always remember that you may be under surveillance (& may be videotaped) from up/across the street, another site, a public area, woods, etc. OSHA does NOT give advance inspection notice.

Know what you can & can’t control.

Things you can (at least somewhat) control:

· The first impression that you give the inspector

· Importance that you & the company place on safety

· Mood during the inspection

· Time spent describing company safety efforts

· Impression of yourself as a competent person

· Hazard identification & correction

· Amount and type of information your give out

Things you have limited or no control over:

· Route taken by the inspector on jobsite

· Employees that inspector interviews

· What inspector videos, photographs, samples, etc.

· Identified alleged violations

· The system, OSHA & our government

DO’s and DON’Ts.

Do’s.

· Ask inspector for photo ID

· Participate in the opening conference

· Be polite, professional & honest (understand that being honest sometimes means politely opting not to answer a question)

· Understand that you are not required to answer questions

· Immediately correct any hazards identified by the inspector

· Explain efforts made to control or eliminate identified hazards

· Take notes & photos (If the inspector takes a photo take one of the same area or issue)

· Ask inspector how to correct alleged violation (if not obvious)

· Know what a competent person is & his/her responsibilities

You are our site competent person based on your experience, familiarity of OSHA regulations applicable to our work and authority to take prompt corrective action to eliminate hazards.

Don’ts.

· Admit guilt or responsibility for an alleged violation

· Panic or lose control of your emotions

· Argue or become belligerent with the inspector

· Lie or deliberately deceive the inspector

· Volunteer information (keep any answers short & concise)

· Leave the inspector to wander your work area by him/herself

· Hamper or interfere with the inspector or inspection process

Take pictures & notes.

Keep a digital or disposable camera handy. Pictures can provide strong evidence to support defense of an OSHA citation. If the inspector takes photos, try to take similar photos at the same time and vantage point. Take photos AS IS – do not “doctor” them. Also, take accurate notes during the inspection (use page 6 of this policy). These too can help us defend against citations.

Closing conference.

When the inspection is complete, the inspector should conduct a closing conference to discuss the results of the inspection. Make sure that you are in attendance, unless you have been informed that we are not being cited. If you find that we are being cited, provide any details, information or other material that may help to show that the alleged hazard did not exist or that we were not responsible for or exposed to it. Again, refrain from admitting guilt to anything.

Submit inspection documentation.

There is a good possibility that your documentation of the inspection will be valuable in building a citation defense if citations are issued for alleged hazards. If you do not understand something, politely ask the inspector to thoroughly explain so that you can provide a reasonable amount of detail in your documentation.

Submit all of the audit documents to the Safety Department at   

[email protected]