EHS Today: OSHA 2009 Site-Specific Targeting Plan: What Your Company Needs To Know
Cleveland partner Patricia Poole, who concentrates her practice in the areas of regulatory compliance and litigation, including occupational safety and health, toxic tort, environmental, employment intentional tort and emergency response, authored an article, "OSHA 2009 Site-Specific Targeting Plan: What Your Company Needs To Know," which was published in the December 2009 edition of EHS Today, the magazine for environment, health and safety leaders.
According to Poole's article: "Each year, OSHA issues a site-specific targeting plan identifying industry sectors with historically high occupational injury and illness rates. The 2009 plan targets manufacturing, non-manufacturing and nursing and personal care facilities. The purpose of OSHA's site-specific targeting (SST) plan is, in fact, to 'target' employers with higher than average rates of injuries in certain industries."
Poole continues: "States with OSHA-approved state plans are required to have their own inspection targeting systems and policies. These inspection policies and procedures must be at least as effective as federal OSHA's 2009 SST."
The article provides information on how OSHA creates the targeting plan, how facilities can be deleted from the list of inspections and what companies should expect during an inspection. "Being prepared for an OSHA inspection is similar to taking an open-book examination," states Poole. "Employers have access to all of the standards on which OSHA will 'test.' The most often cited items are for violations of the hazard communication, lockout/tagout, respiratory protection, powered industrial trucks, electrical and machine guarding standards. All employers, particularly those on the SST-2009 list, should be certain their facilities are compliant with these and all other applicable standards."
Poole goes on to outline the procedures if an employer is cited by OSHA, along with the resolution options available. Poole concludes: "Employers will serve themselves well by closely monitoring their injury and illness rates and maintaining levels below the national average to avoid being included in an OSHA site-specific targeting plan. Employers on the SST-2009 list should be certain they are compliant with all applicable standards, particularly those for which they previously have been cited by OSHA."
Click here to read the full article, "OSHA 2009 Site-Specific Targeting Plan: What Your Company Needs To Know."