Inspection Summaries
Inspection 1
- Facility Name: Cedar Springs Hospital, Inc./Uhs Of Delaware, Inc.
- Date of Inspection: 05/15/2020;
- Initial Penalty: $13,494.00
- Current Penalty: $13,494.00
Summary of Findings
The employer failed to protect the employees from workplace violence in a clinical setting. As a result, employees in direct contact with patients — mental health specialists, registered nurses, and licensed practical nurses suffered concussions, bruising, scratches, and other injuries. In total, 300 employees were exposed to workplace violence in 74 separate instances (OSHA, 2020a). In that regard, the employer failed to develop and implement employee protection measures against recurring workplace violence.
Inspection 2
- Facility Name: Amazon.Com Services Llc.
- Date of Inspection: 02/15/2023;
- Initial Penalty: $15,625.00
- Current Penalty: $15,625.00
Summary of Findings
The employer failed to protect the employees from ergonomic hazards in the workplace. As a result, 250 employees at Amazon DCS3 Delivery Station in Colorado Springs, CO 80925, had to twist, reach, and bend to load heavy packages onto the induct belts (OSHA, 2023). Ultimately, these employees were placed at risk of lower back injuries and musculoskeletal disorders since hazardous work procedures occurred frequently.
Standard Operating Procedure (SOP) for OSHA Inspections
An employer must be prepared for workplace inspections conducted by OSHA. In accordance with Part II, Section D(1), Chapter 3 of the Field Operations Manual (FOM), advance notice of inspections is generally prohibited (OSHA, 2020b). Therefore, Company XYZ must adhere to a specific Standard Operating Procedure (SOP) in order to be prepared for an OSHA visit. The SOP is divided into three parts, describing actions that should be performed in chronological order.
Before OSHA Arrives
A proactive approach is critical for positive outcomes of OSHA inspections. According to Part III, Chapter 3 of FOM, inspections fall into two categories: comprehensive and partial (OSHA, 2020b). Comprehensive inspections cover the whole establishment, whereas partial ones focus on particular aspects, such as workplace safety or health.
However, the inspection algorithm is similar in both scenarios — an opening conference is followed by a walkaround and a closing conference (OSHA, 2020b). Hence, Company XYZ should perform the following standard steps before OSHA arrives.
- A Company Representative must be appointed to conduct all dealings with OSHA officials throughout the inspection.
- A Company Representative must be authorized to handle the following activities related to OSHA inspections:
- Attending the opening and closing conferences;
- Notifying the employees about their rights;
- Accompanying the OSHA official during the walkaround inspection;
- Keeping the inspection under control;
- Responding to OSHA requests;
- A Company Representative must prepare the employees for OSHA interviews. OSHA (2020b) obligates its inspectors to make a reasonable effort to honor employee requests for a union representative or a supervisor. A Company Representative must inform the employees of this right and provide any support they may require to handle the pressure of OSHA interviews. In particular, the employees must be informed on how to react to an OSHA official’s questions during the walkaround inspection.
After OSHA Arrives
Once OSHA arrives at the establishment, a designated Company Representative must participate in the following activities related to the inspection.
Opening Conference
According to OSHA (2020b), a brief opening conference notifies the employer and all affected employees of their rights. A Company Representative must attend the conference to keep the inspection under control by making reasonable requests, such as asking the inspector for credentials.
Walkaround Inspection
Once the opening conference is finished, a Company Representative must accompany an OSHA official throughout the walkaround part of the inspection. According to Part VII, Section F(1), Chapter 3, an inspector can photograph or videotape the workplace (OSHA, 2020b). In that regard, a Company Representative must take their own photographs, videos, notes, or measurements to contest potential OSHA findings.
All Company XYZ staff must communicate with an inspector in a polite and businesslike manner. Additionally, a Company Representative must instruct the employees to refrain from giving an inspector any information unless asked specifically. However, the employees must honestly answer specific questions from an OSHA inspector to create an impression of good faith.
Closing Conference
At this stage, an OSHA inspector demonstrates a Violations Worksheet to inform an employer of apparent violations revealed during the walkaround and interviews (OSHA, 2020b). A Company Representative must ask questions on what standards are cited, the reasons for citing these standards, the gravity of violations, and the severity of penalties. All Company XYZ staff members present at the closing conference must maintain a polite and professional demeanor despite potential disagreement with OSHA findings.
After OSHA Leaves
Arguing with an OSHA inspector is counterproductive. Instead, a Company Representative should notify OSHA where to send the citations to demonstrate good faith. If the Company disagrees with OSHA findings, a written contest must be submitted within 15 working days after receipt of the citation. Additionally, Company XYZ can agree with citations but file a petition to modify the violation abatement date (OSHA, 2020b). If no contests are filed, Company XYZ should correct apparent safety violations to avoid potential penalties for failing to abate the issues.
References
Occupational Safety and Health Administration. (2020a). Violation detail. Web.
Occupational Safety and Health Administration. (2020b). Field Operations Manual. Chapter 3. Inspection procedures. Web.
Occupational Safety and Health Administration. (2023). Violation detail. Web.