Taking a FIRM approach to understanding inspections

The last two columns have described the procedures and rules by which OSHA is bound when writing regulations. In this column, we’ll look at the policies and procedures for inspections. Though not as lengthy and time-consuming as writing regulations, there is an important process for conducting fair and comprehensive inspections.

08/01/2006


The last two columns have described the procedures and rules by which OSHA is bound when writing regulations. In this column, we’ll look at the policies and procedures for inspections. Though not as lengthy and time-consuming as writing regulations, there is an important process for conducting fair and comprehensive inspections.

The guidance for compliance personnel regarding inspections at a workplace are found in the Field Inspection Reference Manual (FIRM), which can be found on the OSHA home page at www.osha.gov . This document consists of nine sections, many of which are routine administrative items such as the cover memo.

The core information, however, consists of four sections, each containing a single chapter. These sections describe pre-inspection procedures, inspection procedures, inspection documentation and post-inspection procedures. The chapters highlight such subjects as inspection scheduling and priority, unprogrammed inspections, conduct of inspections and types of violations. Since this is such a large and comprehensive document, I’ll briefly explain the four chapters that describe the policies and procedures.

Chapter I describes the pre-inspection procedures. It contains information on the responsibilities of compliance personnel, from the regional administrator to the compliance safety and health officer (CSHO). It also explains OSHA’s two types of inspections: programmed and unprogrammed, as well as inspection priorities (e.g., situations involving imminent danger to employees are always top priority).

Chapter II outlines precise procedures for conducting each type of inspection%%MDASSML%% from presenting credentials to the closing conference. Nearly every imaginable facet of an inspection is covered in this chapter. Subjects include: descriptions of both comprehensive and partial inspections; guidance on inspections outside of regular working hours; guidance on CSHO’s signing waivers or releases (they shouldn’t); obtaining warrants (known as “Compulsory Process”); inspections during strikes or labor disputes; trade secrets; and fatality/catastrophe investigations.

Chapter III provides the guidance for how the case file should be documented. This chapter divides the documentation process into four stages: pre-inspection; in-compliance inspection; inspection with citations to be issued; and contested citations. At each stage, the FIRM describes the minimum documentation required and the applicable OSHA forms. More documentation is usually better, of course.

Also included in this chapter is a discussion of affirmative defenses which are “any matter which, if established by the employer, will excuse the employer from a violation which has otherwise been proved by the CSHO.”

Finally, Chapter IV specifies post-inspection procedures. This includes abatement of hazards, verification of abatement and feasibility of proposed abatement. The FIRM provides guidance to CSHOs on determining whether an employer’s claim of infeasibility for a proposed abatement is acceptable. In some cases, the claims may have to be elevated to the appropriate OSHA area director for consideration. Citations and penalties are also discussed in this chapter, including minimum penalties, maximum penalties, and guidelines for assessing penalties. Other subjects covered in this chapter are informal conferences, settlement agreements, the Occupational Safety and Health Review Commission and follow-up inspections.





The Top Plant program honors outstanding manufacturing facilities in North America. View the 2015 Top Plant.
The Product of the Year program recognizes products newly released in the manufacturing industries.
Each year, a panel of Control Engineering and Plant Engineering editors and industry expert judges select the System Integrator of the Year Award winners in three categories.
Pipe fabrication and IIoT; 2017 Product of the Year finalists
The future of electrical safety; Four keys to RPM success; Picking the right weld fume option
A new approach to the Skills Gap; Community colleges may hold the key for manufacturing; 2017 Engineering Leaders Under 40
Control room technology innovation; Practical approaches to corrosion protection; Pipeline regulator revises quality programs
The cloud, mobility, and remote operations; SCADA and contextual mobility; Custom UPS empowering a secure pipeline
Infrastructure for natural gas expansion; Artificial lift methods; Disruptive technology and fugitive gas emissions
Power system design for high-performance buildings; mitigating arc flash hazards
VFDs improving motion control applications; Powering automation and IIoT wirelessly; Connecting the dots
Natural gas engines; New applications for fuel cells; Large engines become more efficient; Extending boiler life

Annual Salary Survey

Before the calendar turned, 2016 already had the makings of a pivotal year for manufacturing, and for the world.

There were the big events for the year, including the United States as Partner Country at Hannover Messe in April and the 2016 International Manufacturing Technology Show in Chicago in September. There's also the matter of the U.S. presidential elections in November, which promise to shape policy in manufacturing for years to come.

But the year started with global economic turmoil, as a slowdown in Chinese manufacturing triggered a worldwide stock hiccup that sent values plummeting. The continued plunge in world oil prices has resulted in a slowdown in exploration and, by extension, the manufacture of exploration equipment.

Read more: 2015 Salary Survey

Maintenance and reliability tips and best practices from the maintenance and reliability coaches at Allied Reliability Group.
The One Voice for Manufacturing blog reports on federal public policy issues impacting the manufacturing sector. One Voice is a joint effort by the National Tooling and Machining...
The Society for Maintenance and Reliability Professionals an organization devoted...
Join this ongoing discussion of machine guarding topics, including solutions assessments, regulatory compliance, gap analysis...
IMS Research, recently acquired by IHS Inc., is a leading independent supplier of market research and consultancy to the global electronics industry.
Maintenance is not optional in manufacturing. It’s a profit center, driving productivity and uptime while reducing overall repair costs.
The Lachance on CMMS blog is about current maintenance topics. Blogger Paul Lachance is president and chief technology officer for Smartware Group.
The maintenance journey has been a long, slow trek for most manufacturers and has gone from preventive maintenance to predictive maintenance.
This digital report explains how plant engineers and subject matter experts (SME) need support for time series data and its many challenges.
This digital report will explore several aspects of how IIoT will transform manufacturing in the coming years.
Maintenance Manager; California Oils Corp.
Associate, Electrical Engineering; Wood Harbinger
Control Systems Engineer; Robert Bosch Corp.
This course focuses on climate analysis, appropriateness of cooling system selection, and combining cooling systems.
This course will help identify and reveal electrical hazards and identify the solutions to implementing and maintaining a safe work environment.
This course explains how maintaining power and communication systems through emergency power-generation systems is critical.
click me