Preparation is key to avoiding common OSHA mistakes

Inadequate training, lack of documentation, and missed inspections are compliance issues that apply across regulations and are easily avoidable. Whether the issue is forklifts, safety data sheets (SDSs), fire extinguishers, or personal protective equipment (PPE), employers need a consistent and effective approach for identifying and addressing workplace hazards. Some simple issues can increase the risk of injuries and result in expensive fines!

Identify hazards in your workplace

Identifying hazards begins with a workplace inspection of equipment and processes that should also include interviews with employees to get a clear picture of workplace risk and exposure. Effective hazard assessments include carefully analyzing inspection data, injury and illness records, and emergency and non-routine events. The results of hazard assessment findings are used to remediate hazards, make improvements, and train workers.

Determine what regulations apply to your organization

Once hazards have been identified, this information can be used to determine what regulations apply to your organization. General industry regulations are found in 29 CFR 1910 and construction at 29 CFR 1926. Many regulations have requirements for training, written plans, and/or inspections; these requirements can guide your efforts to schedule training and inspections and to review any needed written plans. For example, if employees are exposed to hazardous chemicals, the Hazard Communication (HazCom) Standard at 1910.1200 applies; it requires a written program and employee training.

Ensure employees are properly trained

A hazard assessment and review of applicable regulations help determine what training employees need and how often it must be conducted. If a regulation doesn’t specify frequency of training, you may determine what works best for your situation. If a regulation doesn’t mention training – such as the exit routes regulation – or if there’s not a regulation – such as heat exposure – training is needed if it’s a hazard employees are exposed to.

Training must include workplace-specific information. Using the HazCom Standard as an example, workplace-specific information includes things like what chemicals employees are exposed to, how to access SDSs, what’s contained in the employer’s written HazCom program, and the type of labeling system used in the workplace.

Conduct inspections

Know what regulations apply to your situation and check to see if inspections are required (such as for portable fire extinguishers or ladders) and how often. Then, create and implement an inspection schedule. Some regulations have specific inspection documentation requirements and retention periods for such records.

Check your written programs

Some regulations require written programs and, like training and inspections, this depends on whether the regulation applies to your situation. As an example, if employees are required to wear respiratory protection, 1910.134 applies, and the employer must develop and implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use.

It's a best practice to annually review your written programs, even when a regulation doesn’t specify a frequency. Equipment and work procedures can change, leading to changes in your written programs. It’s important to ensure your written plans contain all required elements mentioned in the applicable regulation and reflect what your organization is doing to protect employees and comply with the regulation.