Meat+Poultry - March 2023 - 70

LABOR
Workplace safety net
Every employee has the right to be safe
in the workplace. The Occupational
Safety Health Administration (OSHA)
ensures this right to all workers.
OSHA issues the rules and guidelines,
or " standards, " intended to improve
workplace safety. OSHA enforces
these standards through workplace
inspections and audits, conducting
thousands each year.
PREPARING FOR AN INSPECTION
While employers may have no
control over why or when an OSHA
inspection occurs, employers can
control its results. Internal company
safety audits are among the best steps
employers can take to prepare for an
OSHA inspection. Self-audits permit
employers to identify and address
safety hazards and unsafe practices.
Thorough, wall-to-wall safety reviews
should be conducted on at least an
annual basis.
In addition, confirming that required
OSHA posters are conspicuously
posted and the OSHA 300 logs, 300A
summaries, and 301 incident reports
are all current will avoid common
recordkeeping violations. Similarly,
maintaining and keeping current
training logs, equipment inspection
records, and health/safety policies
permits a complete response to routine
document requests made during
an audit.
THE INSPECTION
OSHA audits begin with an opening
conference during which OSHA
provides the reason and scope of the
audit. A number of documentation
requests will likely be made during
this initial meeting, including selfaudit
reports, training materials and
a list of chemicals stored on site. If
the inspection is in response to a
workplace injury, OSHA will request
documents related to the incident,
including documents relating to the
equipment involved.
All persons involved in the
inspection should be in attendance,
including employees that may
participate. Once the physical
inspection begins, a management
representative should accompany
OSHA officials at all times. If the
inspection is in response to an
accident, the employer representative
should restrict the review to that
work area and relevant equipment.
OSHA may object, but an employer is
within its rights to limit the inspection.
If OSHA insists on inspecting other
work areas, it may be advantageous to
permit it.
EMPLOYEE INTERVIEWS
Most OSHA inspections include
employee interviews. Employers
can and should prepare employees
for potential interviews. Employees
should be informed they can refuse to
speak with OSHA. However, employers
cannot direct employees to refuse to
do so. Failure to prepare employees
could lead to imprecise statements or
admissions by employees who may
not understand the significance of the
process. Employers should advise all
witnesses they are not obligated to sign
any statement prepared by the Certified
Safety and Health Officer, but if they do
so, to request a copy.
THE CLOSING CONFERENCE
Upon conclusion of the inspection,
OSHA holds a closing conference.
OSHA normally explains its findings
and any proposed citations and
penalties. Management representatives
should request the factual basis for any
proposed citations during the closing
conference. The employer should make
all necessary, factual clarifications at
the closing conference.
APPEAL OF CITATIONS
The citation and associated penalties
become a final order if not appealed
within 15 days. An employer should
also request an informal conference
with the OSHA Area Director, which
often results in reduced monetary
penalties, but does not extend the 15day
appeal deadline.
RICHARD D. ALANIZ | meatpoult r y@sos land.com
Failure to prepare employees could lead
to imprecise statements or admissions
by employees who may not understand
the significance of the process.
70 MEAT+POULTRY | 03.23 | www.meatpoultry.com
leremy - stock.adobe.com
http://www.meatpoultry.com
Meat+Poultry - March 2023

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