OSHA Compliance Consulting

Review your programs and documentation, training programs, and recordkeeping. Assess workplace exposures, and conducting industrial and chemical hygiene investigations as required. Areas of expertise include: fall protection; confined spaces; elevated work platforms; respiratory protection and ventilation; lock-out/tag-out; electrical safety; machine guarding; bloodborne pathogens; chemical handing; laboratories, and more.
Under the OSH law administered by Federal and State OSHA (Occupational Health and Safety Administration), employers have a responsibility to provide a safe workplace for their employees. The OSHA regulations cover all industries except mining where MSHA (Mine Safety and Health Administration) rules apply. OSHA rules apply to a wide range of industries with a likewise broad range of hazards. This is a general summary of some key employer responsibilities under OSHA:

  • Provide a workplace free from serious recognized hazards and comply with standards, rules and regulations issued under the OSH Act.
  • Ensure that workplace conditions and your administration of workplace occupational health and safety both conform to applicable OSHA standards.
  • Identify, assess, mitigate and document workplace hazards and preventative and corrective measures.
  • Ensure that employees have and use safe tools and equipment and properly maintain this equipment.
  • Establish or update operating procedures and communicate them so that employees follow safety and health requirements.
  • Provide safety training in a language and vocabulary workers can understand.
  • Use visual means such as signs and labels to warn employees of potential hazards.
  • Post, at a prominent location within the workplace, the OSHA poster (or the state-plan equivalent) informing employees of their rights and responsibilities.
  • Keep records of work-related injuries and illnesses using the OSHA 300 form (reference: 29 CFR 1904.32) Note that employers with 10 or fewer employees and employers in certain low-hazard industries are exempt from this requirement.

There are many occupational health and safety programs required by OSHA and most all include written elements as well as, recordkeeping and employee training. Here is a list of some of the OSHA-regulated activities for general industry (with the 29 CFR Part number referenced for your convenience):

  • Walking-Working Surfaces; Safety requirements for scaffolding (1910.28)
  • Emergency Action Plans (1910.38);
  • Fire Prevention Plans (1910.39);
  • Ventilation (1910.94);
  • Occupational Noise Exposure (1910.95);
  • Non-ionizing Radiation (1910.97);
  • Compressed Gases (general requirements); (1910.101);
  • Process Safety Management of Highly Hazardous Chemicals (1910.119);
  • Hazardous Waste Operations and Emergency response (1910.120);
  • Personal Protective Equipment (1910.132);
  • Respiratory Protection (1910.134);
  • Confined Spaces (1910.146);
  • The Control of Hazardous Energy (lockout/tagout); (1910.147);
  • Medical Services and First Aid (1910.151);
  • Portable Fire Extinguishers (1910.157);
  • Powered Industrial Trucks (1910.178);
  • Overhead and Gantry Cranes (1910.179);
  • Machinery and Machine Guarding (1910.212);
  • Hand and Portable Power Tools and Equipment (1910.242);
  • Electrical Power Generation, Transmission and Distribution (1910.269);
  • Electrical Safety-related Work Practices (1910.331);
  • Bloodborne Pathogens (1910.1030);
  • Ionizing Radiation (1910.1096);
  • Hazard Communication (1910.1200);
  • Occupational Exposure to Hazardous Chemicals in Laboratories (1910.1450);
  • Elevated Work Platforms (1910 Subpart D);
  • Means of Egress (1910 Subpart E);
  • Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms (1910 Subpart F);
  • Hazardous Materials (1910 Subpart H);
  • Personal Protective Equipment (1910 Subpart I);
  • Welding, Cutting and Brazing (1910 Subpart Q);
  • Toxic and Hazardous Substances (1910 Subpart Z);
  • Recordkeeping and Reporting Occupational Injuries and Illness (1904.29).

OSHA has many similar and some different rules for the construction industry and for shipbuilding. Depending upon your location, in addition to Federal OSHA you may fall under State rules which may be more stringent that Federal OSHA.
OSHA’s assessment of safety and health conditions in the workplace depends on a clear understanding of the programs and management systems that an employer is using for safety and health compliance. The Agency places a high priority on safety and health programs and encourages their implementation.
OSHA may assess the effectiveness of your workplace occupational health and safety management system. When doing so, they will conduct a detailed evaluation in order to accurately determine workplace compliance conditions. In January 1989, OSHA published its voluntary Safety and Health Program Management Guidelines which have been widely used in assessing employer safety and health programs. Appendix A of this directive contains the Program Evaluation Profile (PEP), Form OSHA-195, an OSH program assessment instrument used by OSHA compliance officers in conjunction with program-specific assessments. The six main OHS program elements scored in the PEP are:

  1. Management Leadership and Employee Participation.
  2. Workplace Analysis.
  3. Accident and Record Analysis.
  4. Hazard Prevention and Control.
  5. Emergency Response.
  6. Safety and Health Training.

However, to gauge the effectiveness of your OSH management system and programs, we encourage internal and third-party assessments independent of an OSHA investigation. A gap analysis will help identify deficits and assist with the development of corrective measures. We will conduct a mock OSHA to make those assessments for you and then assist with the implementation of program and procedure elements to help you meet OSHA requirements. Please ask us how we may help. Please also view our information on assessments and audits.

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