An Overview of OSHA Regulations and Safety Program Audits at BROWZ

SAFETY AUDITING & OSHA REGULATIONS

Contractor Prequalification & Management | www.browz.com
Presenters
Matt Heap
Safety Manager
Allison Garza
Operations Director, BROWZ
Pat Cunningham
Director, Safety & Auditing
Services

What we ‘ll cover:
• Purpose of the presentation
• About BROWZ auditing & Supply Chain
qualification
• Uploading written safety programs
• Regulatory overview
• How to read an OSHA standard
• BROWZ audit results
• Resources for written safety programs
• Q&A
Agenda

Purpose of the Presentation
Prepare BROWZ suppliers for
upcoming Safety Program
Auditing, OSHA regulations &
insight for writing company
safety programs

• Supply chain assessment &
compliance
• Patented, configurable
technology
• Supply Chain Specialist -
single point of contact for
contractors (suppliers)
• Providing assurance of a safer
work environment
Who is BROWZ?

Good News: More reliance on contractors
Key drivers & increased use of
contractors…
• Lean-hiring practices, access to expertise that’s not available in-house &
flexible employment/staffing models
• Recent Campbell Institute symposium: contractors represent ~ 30% of the
workforce
• Regulatory obligation to evaluate contractors prior to hire
• Qualification process (BROWZ supplier data-base out performed the BLS
national average):
TRR = 57%, DART = 52%, LWD = 60%

First level: Desk top , Client specific, supplier self-disclosure :
• Identified the potential hazard for each steps/task specific to the job
Second level: Safety Program Audit - typically using the BROWZ Standard “Big 6”
(Fall Protection, PPE, Haz Com, EAP, CSE, LOTO)
• Client agreement, on programs to be audited, comparative standard, and element questions
• Some clients may have their own best practice checklists
• Objective: looking for program and element level evidence within a supplier’s written program
Third level: Specialty Audits - Client requested
• These can actually be best practice assessments, or targeted compliance audits that can be
refined down to Consensus standards
• Objective: looking for program and element level evidence within a supplier’s written program
Levels of BROWZ Auditing

• Click , My Account from upper menu
• Click , Environmental – Health – Safety
section in left side menu
• Answer three safety admin. questions
• Click, Document icon below question
• Click , ‘Add’ [Note: 10 MB limit]
• Select file and click ‘Save & Continue’
• Click, ‘Return to Previous Page’ to return to
section
• Click ,‘Save & Continue , or ‘Save Current
Page’ to save answers to questions
Uploading Safety Programs

Regulatory Overview
BROWZ Safety Manual Audits Written at the Federal Level
• State Plan requirements left at the site level (22 State or Territory plans)
• General Industry (1910)
- OSHA uses the term "general industry" to refer to all industries not included in
agriculture, construction or maritime
• Construction (1926)
- Comprises a wide range of activities involving construction, alteration, and/or repair
• Which regulation applies depends on the work, not the employer type

Regulatory Overview
Other Applicable OSHA Information
• General Duty Clause (OSHA Act of 1970, Section 5, “Duties”)
(a) Each employer: (1) shall furnish to each of his employees employment and a place of
employment which are free from recognized hazards that are causing or are likely to cause
death or serious physical harm to his employees; (2) shall comply with occupational safety
and health standards promulgated under this Act.
(b) Each employee shall comply with occupational safety and health standards and all
rules, regulations, and orders issued pursuant to this Act which are applicable to his own
actions and conduct.
• OSHA’s catch-all for citations (after-the-fact, no specific regulation)

Multi-Employer Citation Policy
CPL 2-0.124, published 12/99:
• On multi-employer worksites (all industry
sectors), more than one employer may
be citable for a hazardous condition that
violates an OSHA standard (types of
employers):
- Creating – created the unsafe condition
- Exposing – their employee’s were exposed
- Correcting – responsible for
installation/maintenance
- Controlling – worksite supervisory authority
Regulatory Overview

OSHA Web Page: www.osha.gov
Definitions:
"Shall" = mandatory
"Should" = recommended
Standard Interpretation: Preambles, Letters of Interpretation,
Directives
Industry catch-phrase about OSHA: “If it didn’t get documented, it
didn’t get done”
Notable OSHA Information

Breaking Down the Number: 29 CFR 1910.66(e)(2)(iii)(A)(4)
Subpart: F, Subpart Title: Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms ,
Title: Powered Platforms for Building Maintenance
“Building anchors which extend beyond the face of the building shall be free of sharp edges or points. Where cables,
suspension wire ropes and lifelines may be in contact with the building face, external building anchors shall not interfere
with their handling or operation.”
How to Read an OSHA Standard
Title Code Part Section Lower
Case
Arabic
#
Lower
Case
Roman
Capital
Upper
Case
Arabic
#
29 CFR 1910 .66 e 2 iii A 4

A = General
B = Std. Adoption
C = [reserved]
D = Surfaces
E = Exits
F = Manlifts
G = Health & Enviro.
H = Haz. Materials
I = PPE
J = Enviro. Controls
K = First-Aid
L = Fire Prot.
M = Comp. Gas
N = Hand. Materials
O= Mach. Guarding
P = Port. Tools
Q = Weld. Cutting
R = Spec. Ind.
S = Elect.
T = Diving
U – Y = [reserved]
Z = Toxic Sub.
OSHA Subparts – General Industry (1910)

A = General
B = Interp.
C = S& H
D = Enviro. Controls
E = PPE
F = Fire Prot.
G = Signs, Signals
H = Hand. Materials
I = Tools, Hand/Pow.
J = Weld. Cutting
K = Elect.
L = Scaffolds
M = Fall Prot.
N = Cranes, Hoists
O= Motor Vehicle
P = Excavations
Q = Concrete, Mason.
R = Steel Erection
S = Tunnels, Shafts
T = Demo.
U = Explosives
V = Power Trans.
W = Rollover Prot.
X = Stairways, Ladd.
Y = Diving
Z = Toxic Sub.
OSHA Subparts – Construction (1926)

BROWZ Audit Results – Overview

BROWZ Audit Results – Element Detail

Free Resources:
- OSHA web site, “Small Business”
- Sample programs
- OSHA eTools
- OSHA's On-site Consultation Program
- Journey to Safety Excellence (National Safety Council: free assessment tools & resources)
- Your insurance provider
Resources for a Fee:
- Local Chapters of the National Safety Council (Non-Profit, not in each state)
- National Safety Council (Non-Profit, available nationally)
- Outside vendors – program templates (For Profit, caution: program without thought-investment = “moving a
problem down the line”)
Resources for Written Safety Programs

• Why doesn’t BROWZ provide written templates? independent 3rd party
auditor; belief that each company must engage themselves – assessment,
training, purchasing, maintenance
• Q: Which Standard Applies? (A: 1926 applies for construction operations;
1910 applies for most other operations.) “When in doubt, apply the most
stringent standard.”
• Why can’t we cut/paste OSHA regulations for our Safety Manuals? (OSHA =
‘what’, Company = ‘how’)
Common Supplier Questions

Questions & Contact Info
Matt Heap
Safety Manager
matt.heap@browz.com
Allison Garza
Operations Director, BROWZ
allison.garza@browz.com
Pat Cunningham
Director, Safety & Auditing Services
pat.cunningham@browz.com

An Overview of OSHA Regulations and Safety Program Audits at BROWZ

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