What to Expect When OSHA Arrives Presented by: Tim Pahl and Curt Hassler BalkenTier Consulting Morgantown, West Virginia March 13, 2008 Sponsored by: National Hardwood Lumber Association and Hardwood Manufacturer’s Association

Presented by:

Tim Pahl and Curt Hassler

BalkenTier Consulting

Morgantown, West Virginia

March 13, 2008

What to Expect When OSHA Arrives Topics: Your Risk of Inspection The Inspection Process The Post-Inspection Process Most Common Violations Discussion

Topics:

Your Risk of Inspection

The Inspection Process

The Post-Inspection Process

Most Common Violations

Discussion

Risk of Inspection

Risk of an OSHA Inspection 387 Sawmill Inspections Nationally during 2007 Involved only 36 States 10.3 percent Not Completed due to Out of Business Process Inactive In 2006, 9.3 percent Not Completed In 2005, 11.8 percent Not Completed

387 Sawmill Inspections Nationally during 2007

Involved only 36 States

10.3 percent Not Completed due to

Out of Business

Process Inactive

In 2006, 9.3 percent Not Completed

In 2005, 11.8 percent Not Completed

Risk of an OSHA Inspection Top Five States in Numbers of Inspections (2007) Oregon 60 Missouri 47 North Carolina 41 Washington 21 Virginia 21 Pennsylvania 20

Top Five States in Numbers of Inspections (2007)

Oregon 60

Missouri 47

North Carolina 41

Washington 21

Virginia 21

Pennsylvania 20

2007 OSHA Sawmill Inspections SIC Code 2421 4 WV 20 PA 10 MS 2 ID 9 WI 60 OR 47 MO 2 IA 21 WA 7 OH 10 MI 7 GA 3 VT 7 NY 7 ME 2 FL 21 VA 1 NM 1 MD 2 CT 2 TX 2 NH 1 MA 19 CA 35 TN 2 ND 13 LA 3 AZ 5 SD 41 NC 5 KY 1 AR 3 SC 6 MT 2 IL 4 AL No. Inspections State No. Inspections State No. Inspections State No. Inspections State

OSHA Inspection Data for Sawmills http://www.osha.gov

http://www.osha.gov

OSHA Web Page

When are OSHA Inspections Mandatory? Fatality Catastrophic Incident Involves hospital admission for three or more workers as result of one incident Must report to OSHA within 8 hours 800-321-6742

Fatality

Catastrophic Incident

Involves hospital admission for three or more workers as result of one incident

Inspection Process

Inspection Process Considerations Inspections are Un-announced Order of Priority for Inspections Imminent Danger Fatality or Catastrophic Incident Complaints Programmed Inspections

Inspections are Un-announced

Order of Priority for Inspections

Imminent Danger

Fatality or Catastrophic Incident

Complaints

Programmed Inspections

Can the Compliance Safety and Health Officer (CSHO) be Refused Entry? Employer has the right to refuse entry for an inspection The Regional Solicitor will initiate legal process Inspection Process Considerations

Can the Compliance Safety and Health Officer (CSHO) be Refused Entry?

Employer has the right to refuse entry for an inspection

The Regional Solicitor will initiate legal process

CSHO required to Present Credentials Conduct an Opening Conference Use Appropriate PPE Follow Employer-mandated Safety Practices Inspection Process Considerations

CSHO required to

Present Credentials

Conduct an Opening Conference

Use Appropriate PPE

Follow Employer-mandated Safety Practices

Walk Around Inspection Purpose

Purpose

Walk Around Inspection Purpose Evaluate Employer’s Safety & Health Program

Purpose

Evaluate Employer’s Safety & Health Program

Walk Around Inspection Purpose Evaluate Employer’s Safety & Health Program Identify Apparent Violations

Purpose

Evaluate Employer’s Safety & Health Program

Identify Apparent Violations

Walk Around Inspection Purpose Evaluate Employer’s Safety & Health Program Identify Apparent Violations Collect Samples

Purpose

Evaluate Employer’s Safety & Health Program

Identify Apparent Violations

Collect Samples

Walk Around Inspection Purpose Evaluate Employer’s Safety & Health Program Identify Apparent Violations Collect Samples Take Photographs or Videotapes

Purpose

Evaluate Employer’s Safety & Health Program

Identify Apparent Violations

Collect Samples

Take Photographs or Videotapes

Walk Around Inspection Purpose Evaluate Employer’s Safety & Health Program Identify Apparent Violations Collect Samples Take Photographs or Videotapes Interview Employees

Purpose

Evaluate Employer’s Safety & Health Program

Identify Apparent Violations

Collect Samples

Take Photographs or Videotapes

Interview Employees

Walk Around Inspection Purpose Evaluate Employer’s Safety & Health Program Identify Apparent Violations Collect Samples Take Photographs or Videotapes Interview Employees Offer Abatement Assistance

Purpose

Evaluate Employer’s Safety & Health Program

Identify Apparent Violations

Collect Samples

Take Photographs or Videotapes

Interview Employees

Offer Abatement Assistance

Walk Around Inspection Written Documentation OSHA Poster

Written Documentation

OSHA Poster

OSHA Poster

Walk Around Inspection Written Documentation OSHA Poster Written Safety & Health Programs

Written Documentation

OSHA Poster

Written Safety & Health Programs

Walk Around Inspection Written Documentation OSHA Poster Written Safety & Health Programs OSHA Form 300, 300A, and 301

Written Documentation

OSHA Poster

Written Safety & Health Programs

OSHA Form 300, 300A, and 301

Walk Around Inspection Written documentation OSHA Poster Written Safety & Health Programs OSHA Form 300 Training Records

Written documentation

OSHA Poster

Written Safety & Health Programs

OSHA Form 300

Training Records

Walk Around Inspection Workplace Hazards Machine Guards Container Labels Posting/Barriers to Hazardous Areas Screens or Other Devices to Protect Workers Emergency Stop Devices ROPS & FOPS on Mobile Equipment Unstable Stacks of Lumber

Workplace Hazards

Machine Guards

Container Labels

Posting/Barriers to Hazardous Areas

Screens or Other Devices to Protect Workers

Emergency Stop Devices

ROPS & FOPS on Mobile Equipment

Unstable Stacks of Lumber

Walk Around Inspection 29 CFR 1910.265 Sawmills Includes sections on Buildings, Facilities, Isolated Equipment Log Breakdown and Related Equipment Dry Kilns and Facilities Personal Protective Equipment Sanitation Fire Protection

29 CFR 1910.265 Sawmills

Includes sections on

Buildings, Facilities, Isolated Equipment

Log Breakdown and Related Equipment

Dry Kilns and Facilities

Personal Protective Equipment

Sanitation

Fire Protection

Closing Conference Purpose Describe apparent violations and other pertinent issues Provides opportunity for employer to provide information

Purpose

Describe apparent violations and other pertinent issues

Provides opportunity for employer to provide information

Closing Conference Purpose Describe apparent violations and other pertinent issues Provides opportunity for employer to provide information Second Closing Conference If all pertinent information is not available for the initial closing conference

Purpose

Describe apparent violations and other pertinent issues

Provides opportunity for employer to provide information

Second Closing Conference

If all pertinent information is not available for the initial closing conference

Post Inspection Process

Cover Letter Citation and Notification of Penalty Invoice/Debt Collection Notice Three Path Choices Accept OSHA’s Findings Request an Informal Conference Contest OSHA’s Findings Follow-up Inspection Post Inspection Process

Cover Letter

Citation and Notification of Penalty

Invoice/Debt Collection Notice

Three Path Choices

Accept OSHA’s Findings

Request an Informal Conference

Contest OSHA’s Findings

Follow-up Inspection

Post Inspection Cover Letter

Citation and Notification of Penalty

Citation and Notification of Penalty

Citation and Notification of Penalty

Citation and Notification of Penalty

Invoice/Debt Collection Notice

Cover Letter Citation and Notification of Penalty Invoice/Debt Collection Notice Three Choices: Accept OSHA’s Findings Request an Informal Conference Contest OSHA’s Findings Post Inspection Process

Cover Letter

Citation and Notification of Penalty

Invoice/Debt Collection Notice

Three Choices:

Accept OSHA’s Findings

Request an Informal Conference

Contest OSHA’s Findings

Accept OSHA’s Findings Post Inspection Process Abate Violations Provide Certification/Documentation of Abatement Pay Proposed Financial Penalties

Accept OSHA’s Findings

Abate Violations

Provide Certification/Documentation of Abatement

Pay Proposed Financial Penalties

Post Inspection Process

Request an Informal Conference Post Inspection Process

Request an Informal Conference

Post Inspection Process

Contest OSHA’s Findings Post Inspection Process

Contest OSHA’s Findings

Cover Letter Citation and Notification of Penalty Invoice/Debt Collection Notice Three Path Choices Request an Informal Conference Accept OSHA’s Findings Contest OSHA’s Findings Follow-up Inspection Post Inspection Process

Cover Letter

Citation and Notification of Penalty

Invoice/Debt Collection Notice

Three Path Choices

Request an Informal Conference

Accept OSHA’s Findings

Contest OSHA’s Findings

Follow-up Inspection

Most Common Violations

Most Common Violations October 2006 – September 2007 Flammable and combustible liquids $27,683 31 59 1910.106 Eye and face protection $11,939 29 35 1910.133 Hand & portable powered tools & equipment $25,003 59 59 1910.242 Sawmills $76,228 38 101 1910.265 Portable fire extinguishers $25,223 75 96 1910.157 Occupational noise exposure $93,091 100 176 1910.095 Powered industrial trucks $111,841 136 220 1910.178 Hazard communication $50,861 167 337 1910.200 Wiring Methods, components, equipment $125,522 169 313 1910.305 Lockout/Tagout $259,607 193 364 1910.147 Description Penalty # Insp # Cited Standard

What to Expect When OSHA Arrives Review: Your Risk of Inspection The Inspection Process The Post-Inspection Process Most Common Violations

Review:

Your Risk of Inspection

The Inspection Process

The Post-Inspection Process

Most Common Violations

What to Expect When OSHA Arrives Sponsored by: National Hardwood Lumber Association and Hardwood Manufacturer’s Association Presented by: Tim Pahl Curt Hassler BalkenTier Consulting Morgantown, West Virginia March 13, 2008 Tim Pahl 304-276-0946 Voice [email_address] Curt Hassler 304-282-5417 Voice [email_address]

Sponsored by:

National Hardwood Lumber Association

and

Hardwood Manufacturer’s Association

Presented by:

Tim Pahl

Curt Hassler

BalkenTier Consulting

Morgantown, West Virginia

March 13, 2008

Tim Pahl 304-276-0946 Voice [email_address]

Curt Hassler 304-282-5417 Voice [email_address]