An OSHA Compliance Officer paid a surprise visit to one of our customers recently. This is a manufacturing customer that employs about 250 people in 250,000 square feet. After an opening conference with the plant manager, the union president, and the maintenance and tooling general supervisor, he started his wall-to-wall physical inspection in the afternoon and completed it the next morning. After the physical inspection, he reviewed our documentation.
We did very well. In our closing conference, the compliance officer said he would recommend to his area director that we be cited for only one violation. That citation was for failure to use die blocks during press setup. He observed two such incidents while touring the press room. He said this is a medium-serious violation. We were fined about $2,500 but received a discount for not contesting the citation. We immediately reinstructed all press room employees in the proper procedure.
The compliance officer emphasized that we “need to be complimented.” He said that he would normally find 20-25 violations in a plant this size. This did not surprise us since we strive to keep our customers in a state of readiness at all times for an OSHA inspection.
The documents he requested included:
- OSHA 300 Log
- Hazard Communication Program and MSDS
- Lockout Tagout Program and Machine Specific Lockout Procedures
- Crane Inspections
- Mechanical Power Press Inspections
- Respirator Program
- Hearing Conservation Program
- Plant Safety Rules
He requested no training records. He did ask if we trained employees in the MSDS specific to a department upon initial assignment or transfer to another department.
Plant inspection items that he emphasized included:
- Housekeeping (he feels this makes a good initial impression)
- Eye Wash Stations (asked how often we serviced them)
- Container Labeling
- Third Prong on Electrical Plug Intact
- Damaged Insulation on Flexible Wiring
- Electrical Polarity
- Press Brake Guarding (suggested we move the 2-hand trip station further away from the Pacific press)
- Grinder Guarding
- Guarding on Unused Portion of Band Saws
- Press Room Guarding (he was impressed with our extensive use of light curtains and brake monitors)
- Miscellaneous Guarding (he suggested we add some guarding to a Bridgeport drill press in the tooling department)
- Grounding in Paint Vault
- Fire Extinguisher Monthly Inspections
- Condition of Welding Machines