The story goes like this ... You're sitting at your desk when you're informed that someone from Cal/OSHA has just arrived for an "unannounced drop-in" inspection. You ask yourself, what could they possibly want? Well hang on to your hats because the inspector wants to see everything.
Since we are all seeing more and more government agencies looking for ways to get into your wallet, I thought it appropriate to share with you the list of items Cal/OSHA is now demanding. This so you can be prepared in case you are visited by one of the many agencies now actively looking to levy fines.
- Facility Layout (i.e. Floor plan, process flow diagram, equipment map, etc.) L/C 6313(a)
- Cal/OSHA Log 300 (Current year and the previous 5 years) T8CCR14301(b)
- No. of employees for 2012_______No. of employee hours for 2012________
- Cal/OSHA 5020 (Employer's First Report of Injury/Illness). T8CCR14304(a)
- Cal/OSHA 5021 (Doctor's First Report of Injury/Illness). T8CCR14007
- Workers Compensation Insurance "Experience Modification" Worksheet. L/C6314.1
- Injury and Illness Prevention Program (SB198-T8CCR3203(a)
- Inspection Records T8CCR3203(b);Training Record T8CCR3203(b)
- Safety Committee Meeting Minutes (if used) T8CCR3203(c)
- Emergency Action Plan T8CCR3220
- Fire Prevention Plan T8CCR3221
- Hazard Communication Program T8CCR5194(e)
- Material Safety Data Sheets (MSDS) T8CCR5194(g)
- Respiratory Protection Program T8CCR5144(f)
- Hearing Conservation Program (Noise) T8CCR5097(a)
- Workplace Exposure Records (Airborne contaminants, noise, etc.) T8CCR5155(e)
- Permits T8CCR341, 461 (e.g. Air tanks/compressors)
- Maintenance records for equipment (Various Sections of T8CCR)
- Forklift Training Records
- Business License Numbers
- Lock Out/Tag Out Program
- Other (This is a catch-all just in case they forgot something)
The various items requested come from a Cal/OSHA Document Request Sheet. Many of them will not apply to your particular situation. However, it offers you an excellent roadmap to follow as you review the current status of the various items that do apply to you.
It is also important to review the various posters that must be displayed. When making a physical inspection, you will be asked to show where they are posted and that they are current. The following is a list of what you need and where you can find them.
- Labor Law — You can purchase a complete poster from the California Chamber. The cost is $32 dollars each for English and Spanish and you will probably need both. Their number is 800-331-8877 to order.
- As an added bonus, you will also get the new NLRA poster. The newest effective date for posting is 1 April 2012. You will need to post this one as well.
- Wage Orders – Those specific to your industry must also be posted. You can visit http://www.management-advantage.com/products/IWCOrders.htm and then select the one that is most appropriate for your situation.
Finally, effective 1 January 2012 there is a new "Notice to Employee" form that needs to be given to each NEW employee at time of hire. It is mandated under Labor Code section 2810.5 and may be found at www.dir.ca.gov/DLSE.
And Just In Case You Think The State Is Not Serious ...
Cal/OSHA just issued citations, with penalties of $256,445 against a warehouse operator and its temp staffing contractor following nine inspections of four warehouses in Chino.
The investigators uncovered 31 general and 29 serious violations. There were also two serious, accident-related and two regulatory citations issued.
Two fines of $18,000 each were for failure to implement an Injury and Illness Prevention Program (IIPP) at one of the warehouses. These were for a situation where one of the workers suffered serious heat illness. Serious citations were also issued for failure to provide fall protection systems for workers, unstable storage stacks, unlocked bailer and compactor controls, and numerous unguarded machines. They also got written up for failure to enforce forklift speed limits and problems with emergency eye washes.
They were also cited for unsafe electrical systems, lack of personal protective equipment, the lack of a heat related prevention program and an ineffective injury and illness prevention program.
So You Ask "What Should I Do?"
Review all of the related programs listed above for current compliance. Inspect your physical plant for potential violations. You should be able to request help from the Loss Control department of your current workers compensation carrier. They usually have a staff of experts that can come to your facility and help identify solutions.
This article is an excerpt from the February 2012 edition of From The Hotline published by Stuart Baron & Associates and Workers' Compensation Claims Control. It is used with permission under the copyright of Stuart Baron & Associates.
