Fact
Sheets: Worksite Inspections
Union Representatives as
Detectives
The only way to
know whether your work place -- and that of your
coworkers -- is safe is to inspect it.
The main purpose of the actual workplace inspection is
for the inspector(s) to discover health and safety
hazards and get them corrected before injuries or
illnesses occur. A closely related purpose is to educate
the workers about the hazards they face at work. Not
only must union representatives take part in all
inspections, but all employees should be aware that an
inspection is taking place and feel free to tell
inspectors of any problems they may be having.
TALK TO WORKERS
The primary goal of any effective union health and
safety program is to prevent workers from being injured
or becoming ill from the hazards they face on the job.
To do this, union representatives must be detectives:
listening to workers' health and safety complaints,
inspecting the workplace, investigating accidents and
using accident and illness records.
Talking to workers is the most important piece of what
union activists should do about trying to solve health
and safety problems. No one knows better what problems
exist in the workplace and, often, what the best
solutions are, than the people who work there every day.
Simply talking to each other and listening is the
starting point for worksite inspection.
THREE STEPS FOR A WORKSITE INSPECTION
There are three distinct segments of any workplace
inspection, whether it is an inspection of the worksite
by OSHA or by the union as part of a joint
labor/management worksite inspection.
1.Opening Conference
The first part of the inspection is the "opening
conference." This is simply a meeting between the
employer, the union representative and the OSHA
inspector (or in the case of an inspection by a joint
committee, the inspection team) before the actual
walk-around inspection begins.
It is possible to have separate opening conferences for
labor and management before an official OSHA inspection
if workers feel intimidated talking to the OSHA
inspector in management's presence.
In the opening conference, the parties review existing
programs and policies, look at injury and illness data
which OSHA requies the employer to keep, and generally
prepare for the walk-around.
Examples of the programs and policies which
should be consulted include:
-
any written health and
safety policy;
-
the right-to-know or
hazard communication training program;
-
a confined space entry
program;
-
a respiratory
protection program;
-
emergency response plan
including evacuation routes, emergency phone
numbers, etc.;
-
traffic safety and
control procedures for highway and public utilities
crews.
In
addition, at the opening conference, the Annual Log
of Occupational Injuries and Illnesses (OSHA 200 or
state equivalent) should be reviewed by the inspector or
inspection team. The inspector(s) should also review the
training records which are required to be kept by OSHA
under the Hazard Communication Standard (1910. 1200 or
state equivalent) and the Respiratory Protection
Standard (1910.134).
The inspector(s) should consult the written Hazard
Communication (Right-to-Know) Program, become familiar
with the list of chemicals to which employees are
exposed and review the material Safety Data Sheers
(MSDS) maintained by the employer.
In addition, the inspectors should look at medical,
exposure, injury and illness, accident records and any
other information which may be used to determine the
effectiveness of the health and safety program and
whether the program complies with OSHA standards.
2.The Walk-Around Survey
The inspection should be performed during normal
working hours while employees are engaged in their
normal day-to-day activities. If employees are not
around, the inspectors can't talk to them and important
problems could be missed.
Ideally, inspections should be conducted once a month,
but the actual frequency may have to be negotiated.
Inspections by the local union only may be performed
without management's presence and may be as frequent as
the local wishes to make them.
Whatever the frequency of inspections, the worksite
should be reinspected whenever there is a change in work
methods, processes, or in the chemicals and tools used.
This is to make sure that these changes are not damaging
the health and safety of our members.
Several important points need to be made about
conducting the worksite inspections:
-
Be especially alert.
Use your senses of sight, smell and hearing as you
inspect. Notice how you feel while working or
inspecting.
-
Make a map of the
worksite.
Draw a diagram or get a copy of the floor plan from
the employer. Use it to identify certain processes
and areas where you find hazards.
-
Take good notes.
Identify the location of the hazard, who is affected
by it, and if it is a routine or non-routine
operation. These notes can be very helpful later.
-
Take photographs.
Polaroids can provide evidence right away. But 35 mm
take better pictures. Take both if you can.
-
Write a Report.
After the inspection, write a report of all the
health and safety problems that were identified
during the inspection. Cite the OSHA standard(s)
violated, if any. Request that corrective measures
be taken as soon as possible. If it is a union only
inspection, submit a copy of the report to the Joint
Committee or give a copy to management. Be sure to
keep several copies for the local union.
A
checklist may be very helpful in conducting the worksite
inspection. Certain areas of the worksite may be
forgotten and not inspected or certain hazards may not
be found by the inspector. The use of checklist will
help to avoid this problem.
The following list of sample inspection questions are
representative of the kinds of questions which should be
mentioned on a checklist. More extensive checklists are
available in the TWU Safety and Health Department
or from your TWU representative.
-
Have there been any
recent accidents/near misses?
-
Are workers trained to
operate the equipment properly?
-
Are fire exits marked
properly? Is access to fire exits blocked in any
way?
-
Have workers been
trained about the chemicals they may be exposed to?
Are Material Safety Data Sheets available?
-
Does the area seem hot,
cold, noisy, or stuffy? Are chemical odors evident?
-
Do workers ever
complain of headaches, dizziness, watering eyes or
sore throats?
-
Do machines have all
the necessary guards around moving parts and drive
belts? Are all stairways and walkways clear? Are
hardhats, safety shoes, gloves, respirators, and
other personal protective equipment provided when
necessary?
-
Do people lift, carry,
push, or drag heavy loads? If lifting, do they lift
properly? Can the job be changed or mechanical
equipment used to reduce the heavy lifting workers
must do?
3.The Closing Conference
After the
inspection has been completed, all violations recorded,
and the findings re-viewed, the last step in the
inspection process is to hold what OSHA calls the
"closing conference." Like the opening
conference, it is a meeting between the employer, the
union representative, and the OSHA inspector (if any).
At this conference, the findings of the inspection will
be reviewed with management and the union. If it is an
official OSHA inspection, standards and possible
abatement (correction) dates will be discussed.
If it is a labor management inspection, violation of
OSHA standards and/or employer safety policies will be
reported. The written policies, programs, and plans of
the employer should be evaluated and discussed.
Correction of unsafe conditions and improvements in
safety and health programs should be recommended during
this conference and completion dates set.
A summary of the inspection report as well as the
minutes of health and safety committees should be posted
on the union bulletin board or distributed to workers in
newsletters. If an OSHA inspection results in a
citation, a copy of the citation must be posted near the
area where the violation occurred.
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